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these Defendants, some of whom have been 
tagged by the press as "contrapreneurs/' 
represent the very epitome of organized crime, 
but on an international stage. They deal 
wholesale in narcotic drugs, illegal weapons 
and violence. Rather than take over local 
businesses or undermine local government, they 
seek to take over whole nations. They do not 
hesitate to murder and destroy anyone or 
anything that gets in their way. By any 
dePmition, these Defendants, alleged merchants 
of heroin and terrorism, are organized 
criminals on a scale larger-than-life.'* 

Filed on December 12, 1986 
(Minor Revisions January 31, 1987) 



If information contained in this Affidavit is reprinted, 
rcbroadcast, or used in any way, we ask that you credit 
the Christie Institute, an intcrfaith, public interest 
law firm and public policy center. 

The Christie Institute 
1324 North Capitol Street, NW 
Washington, DC 20002 
(202) 797-8106 



r I* 

Table of Contents 

Acknowledgement j 

Introduction • ii 

The Investigation Begins 4 

"State Defense Forces'* and a "Guns for Contras" Scam 

American Mercenaries and the Contras 9 

A Honduran Meeting (9); An American Mercenary's Diary 
(11); A White House Connection: North, Posey and Owen 

Official, Covert U.S. Government Aid to Contras I3 

Reagan Orders the CIA to Back the Contras (15); A 
Congressional ban on "Direct or Indirect" Aid (16); The 
"Privatization" of the Contra War (16) 

The Hull Terror-Drug Operation: A Defector's Story j7 

Cocaine and a Plan to Assassinate a U.S. Ambassador 
(19); Contra Cocaine to the U.S. (22); The La Penca 
Press Conference Bombing (23); Kidnappings, Death 
Threats, and Murder (26) 

The Secret Team 2S 

The Wilson Connection in Iran (28); Supplying the 

Contras (30) 

The First "Contra War": Organized Crime and Right-wing 

Terror-Politics j2 

The Move to Southeast Asia: Political Assassination Financed 

by Opium 

The Birth of the Secret Team (36) 

Post-Vietnam: Drugs, Arms Scams and Terror Continue 37 

Early "Iran Arms Deal" Profit-Skimming (39) 

The Contra Connection: The Secret Team Bargains with Somoza 40 

The CIA Takes the Ball (41); North Turns to the Secret 
Team When Congress Bans Aid (42) 

White House Uses Secret Team Again for Iranian Arms Deal 

Profits go to the Contra Operations 42 


Photographs and Selected Index ! ! [ ! ] [ \ ] \ \ \ \ \ ] ; ; ; ; ; ~ 


7^' document which you are about to read is derived from the most 

comprehensive investigation, public or private, of the private 
individuals involved in the Iranscam/Contragate affair. Months before 
he Reagan Administration's admission that arms were sent to Iran a 
lawsuit based on this investigation named the principal figures and 
described their methods. 

J^]! of years of investigative 

work by the Christie Institute's professional private investigators; by 
the plaintiffs. U.S. journalists Tony Avirgan and Martha Honey; and by 
other investigative journalists. Its goal is to expose and bring to 
justice the "Secret Team" of people which worked with the Reagan 
Administration, through Lt. Col. Oliver North, to smuggle weapons to 
Iran and to the Contras. This private operation has long been funded 
by the sale of illegal narcotics in the United States. 

The lawsuit is the only investigation outside of the federal 
government empowered to use federal subpoena power to develop a legal 
Vecord of truth" regarding this constitutional crisis. The legal team 
IS already sharing information with the United Stated Congress 
Investigative journalists now acknowledge that "this is bigger than 
Watergate" and the Christie Institute is their primary private source 
on the history and activities of the Secret Team. 

The Christie Institute is a public interest, intcrfaith law and 
public policy center. It has a reputation for through, professional 
private investigations that result in significant legal victories It 
IS best-known for launching and directing the successful Karen Silkwood 
case. In 1985. the Institute won a civil judgement against the Ku Klux 
Klan. the American Nazi Party, and the Greensboro Police Department 
after state and federal prosecutions failed to obtain convictions for 
the murder of peaceful anti-Ktan demonstrators. 

The Affidavit 

This affidavit is an unusual filing in a federal civil lawsuit 
To advance to pre-trial investigation. Attorney Daniel Shcchan the 
Plaintiffs- Chief Counsel and General Counsel of the Christie Institute 
has submitted this sworn statement describing the results of three 
years of private investigations. In it, he lays out a detailed 
specific narrative of the defendants" criminal activities and' the 
Christie Institute's investigation of them. 

In the face of indifference and interference bv the Reagan Justice 
Department. Christie Institute attorneys are acting as prosecutors 
using the RICO (Racketeer Influence and Corrupt Organization Act) 
Statute which was passed in 1970 to fight organized crime. Here RICO 


is the cornerstone of an effort to prove the existence of the illegal, 
private Contra support network involved in gunrunning, drug smuggling, 
murder, political terrorism and other crimes and to bring its members 
to justice. Leaders of this same network helped the Reagan 
Administration secretly smuggle weapons to the government of Iran. 

Created without use of federal subpoena power, the Affidavit 
demonstrates the wealth of evidence available to those willing to look 
for it. The sources have been kept, for the most part, anonymous. 
Some seek immunity from criminal prosecution; others will testify only 
if subpoenaed and forced to answer under oath; and many need to be 
assured of their personal safety. 

They include law enforcement officers, curren^ and former high 
ranking officials of the Central Intelligence Agency and the Drug 
Enforcement Agency, American mercenaries, individual contras, drug 
smugglers and the pilots who have flown from the U.S. carrying guns and 
returned with cocaine. 

Because it summarizes an on-going investigation, minor revisions 
have been made as new information becomes available. If information 
contained in this Affidavit is reprinted, rebroadcast, or used in any 
way, we ask that you credit the Christie Institute, an interfaith, 
public interest law firm and public policy center. 

Sheehan's investigation grew out of his work on the first 
Sanctuary Movement defense case. In early 1984, he learned of Reagan 
Administration contingency plans in the event of large scale U.S. 
military action in Central America. The Federal Emergency Management 
Agency (FEMA) had proposed imprisoning some 400,000 Central American 
refugees already in the U.S. and the "deputizalion" and arming of 
"State Defense Forces" civilians and military personnel intended for 
domestic law enforcement. 

According to sources within FEMA, a clandestine scheme to provide 
weapons to the Contras had been proposed under the cover of a FEMA 
training exercise. Weapons were to be dispersed to these local State 
Defense Forces and then transferred to the Contras. Private networks 
of American contra supporters were to handle the transfer of weapons. 
Additional information on these private networks came to Shcchan 
through a U.S. reporter with close contacts to American mercenaries. 
With his help, Sheehan learned of the Reagan Administration's efforts, 
directed by Lt. Col. Oliver North, to defy Congressional restrictions 
and the eventual Congressional ban on aid to the contras by using 
private war-makers. 

Meanwhile, the plaintiffs, journalists Tony Avirgan and Martha 
Honey, had been conducting their own investigation of the contras and 
their U.S. supporters. Avirgan, while an ABC News cameraman, was 
severely injured at the 1984 bombing of a press conference in La Pcnca, 
Nicaragua. Supported by ihe Committee to Protect Journalists and the 
Newspaper Guild, they discovered an "International Brigade" of 


gunrunners and terrorists fighting on behalf of the contras and based 
in Costa Rica. 

Avirgan and Honey identified this Brigade's main base to be 
American John Hull's Costa Rican land holdings. Airstrips on Hull's 
ranch helped transport both weapons and cocaine. The two reporters 
discovered that this same group of men carried out the press conference 
bombing and had planned to assassinate the U.S. Ambassador to Costa 

In 1985, Avirgan and Honey began sharing their information with 
Sheehan. Sheehan's sources within the American intelligence community 
soon led him to uncover, long before the public exposure of the Iran 
Arms deal, a "secret team" of former high ranking Central Intelligence 
Agency and U.S. military officials. 

The Affidavit outlines this Secret Teams's history of political 
assassination and arms trafficking funded by drug smuggling which begin 
in the early 1960's. Sheehan's sources recount the team members' work 
with anti-Castro Cuban terrorists and their leadership of 
■unconventional warfare" programs in Southeast Asia. Sheehan's sources 
told him of the development of a partnership there between opium 
traffickers and the Secret Team, a continuing partnership which 
provides the funding for independent, "black" operations after the 
Vietnam War. 

Later, while helping the Shah of Iran eliminate his opponents, the 
Team made the connections which would be later used by the Reagan 
Administration in the arms for hostages deal. When Nicaraguan Dictator 
Anastasio Somoza was cut off from U.S. aid by the Carter 
Administration, the Team stepped in with weapons and ammunition. They 
were the Contras' primary early suppliers and later worked with the 
Reagan Administration both before and after the Boland Amendment banned 
any "direct or indirect" government aid to the contras. 


Below, the Plaintiffs' attorney, Daniel P. Shcehan, sets forth for the 
Court in the following Affidavit, the explanation of the evidence presently in 
his possession which evidence does, in fact, rise to the level of "probable 
cause" to believe that the Defendants named in this federal civil lawsuit are 
guilty of the commission of the federal criminal violations set forth in the 
Amended Complaint of October 4, 1986. The Plaintiffs move that this Affidavit 
of Counsel be deemed a Supplemental Filing to their October 4, 1986, Amended 
Complaint if the Court deems this to be legally required and that it be deemed 
by the Court to set forth the evidentiary basis upon which a reasonable person 
- drawing all logical inferences from the facts adduced in the direction of 
the Plaintiffs - would conclude that it is more probable than not that each 
of the Defendants named in this civil suit is guilty of violating the Federal 
RICO Statute and that each is civilly liable to the Plaintiffs Tony Avirgan 
and Martha Honey for having fortuitously contributed to the civil wrongs 
committed against them as charged in this Amended Complaint as Supplemented 
by the Affidavit of Counsel. 


Now comes Attorney Daniel P. Shcehan, and having been duly sworn hereby 
swears and affirms that the following facts are true: 

1. I am a duly licensed attorney at law, admitted to practice before the 
State and Federal Courts of the State of New York in both the Northern and 
Southern Districts of New York. 

2. I am duly licensed and have been admitted to practice before the Courts 
of the District of Columbia, both local and Federal and I am in good standing 
before both the Bar of New York and the Bar of the District of Columbia. 

3. I have practiced law before the courts of New York and numerous other 
states in our nation since 1970, having served as counsel in some 60 separate 
pieces of litigation in the states of New York, Pennsylvania, North Carolina, 
Virginia, the District of Columbia, Georgia, Florida, Oklahoma, Ohio, 
Colorado, Idaho, Nebraska. South Dakota, Wyoming and Mississippi; 

4* I graduated from Harvard College in 1967 as an Honors Graduate in 
American Government, writing my Honors Thesis in the field of Constitutional 
Law, and was the Harvard University nominee for the Rhodes Scholarship from 
New York in 1967. I graduated from Harvard School of Law in 1970, having 
served as an Editor of the Harvard Civil Rights-Civil Liberties Law Review and 
as the Research Associate of Professor Jerome Cohen, the Chair of the 
International Law Department of Harvard. 

5. While at Harvard School of Law, I served as a summer associate at the 
State Street law firm of Goodwin, Proctor and Hoar under the supervision of 
Senior Partner, Donald J. Hurley, the President of the Boston Chamber of 
Commerce and Massachusetts Senatorial Campaign Chairman for John F. Kennedy. 




At this firm I participated in the case of BAIRD v EISENSTAT, under Roger 
Slockcy, General Counsel for the Massachusetts Planned Parenthood League 
(establishing the unconstitutionality of the Massachusetts anti-birth control 
law) and in the Nevada case, under Charles Goodhue, III (establishing the 
constitutional right to bail in criminal extradition cases, including capital 

While at Harvard School of Law, I authored "The Pedestrian Sources of 
Civil Liberties" in the Harvard Civil Rights-Civil Liberties Law Review and 1 
served under Professor Milton Katz, the President of the International Law 
Association, as the Chairman of the Nigerian Biafran Relief Commission 
responsible for successfully negotiating the admission of mercy flights of 
food into Biafra in 1968. 

6. While serving as a Legal Associate at the Wall Street law firm of Cahill, 
Gordon, Sonnett, Reindcl and Ohio under partner Floyd Abrams and in 
association with Yale Law School Professor of Constitutional Law Alexander 
Bickel, I participated in the litigation of such cases as the UNITED STATES v 
THE NEW YORK TIMES (establishing the constitutional right of The New York 
Times to publish the Pentagon Papers); UNITED STATES v BRANZBERG (litigating 
the First Amendment right of professional journalists to protect the identity 

of confidential news sources) and THE NEW YORK TIMES v THE JEWISH DEFENSE 
LEAGUE (establishing the right of newspapers to refuse to publish proffered 
paid political advertisements of their choosing). 

While a Legal Associate of the Cahill, Gordon law firm, I was appointed 
by New York City Mayor John Lindsey to be Legal Counsel to the Inmate 
Association of the Manhattan House of Correction and was admitted to practice, 
pro hoc vice before the United States District Court for the Western District 
of New York with Professor Herman Schwartz in the case of IN RE ATTICA PRISON 
INMATES V MANCUSO (which caused the reversal of the official New York State 
Coroner's Autopsy falsely certifying that all 41 hostages held by the inmates 
at Attica prison had been killed by having their throats cut by the inmates — 
whereas, in fact, all 41 hostages had been killed by the gunfire from New York 
State Police into Attica Prison's exercise yard from the parapets surrounding 
the prison.) During this period, I also served as public interest counsel in 
the case of CORTIGHT v. RESOR, (establishing the First Amendment Right to 
Freedom of Expression of US Servicemen); in the case of IN RE LINDA JENESSE 
(establishing the right of appearance on the ballots of New York of all 
candidates who obtained the legally required numbers of signatures on their 
(establishing the First Amendment right of candidates for public office to the 
use of public park facilities). 

7. In 1972, I served as the New York States Assistant Campaign Director in 
Charge of Voter Registration for George McGovern for President and the New 
York State Democratic Party; and as Special Counsel to the Scott Commission 
associated with the Knapp Commission investigation of New York City police 

8. I then practiced as Litigation Associate to F. Lee Bailey in the Boston 
Law firm of Bailey and Alch during the period when Gerald Alch was 
representing James McCord, the electronic eavesdropping specialist in the 
Watergate Burglary Case - the man who wrote the letter to Judge John Sirica 


revealing the direct involvement of then President Richard M. Nixon and high- 
ranking White House personnel in the unconstitutional Huston Plan and the 
unlawful covcr-up activities in the Watergate Burglary Case. 

9. 1 also served as Chief of Litigation for the national American Civil 
Liberties Union office in the Rocky Mountain States where I served as Chief 
Trial Counsel in some one dozen trials - including the First Amendment 
criminal defense of the United Artist film "LAST TANGO IN PARIS"; the 
successful Federal Civil Rights Act civil prosecution of the members of the 
Idaho State Board of Education in LYMAN v SWARTLEY, et al. for the unlawful 
termination of American Federation of Teachers union organizer Rufus Lyman 

from the Idaho State University; UNITED STATES v STARR (dismissing Rap Brown 
Act charges against students arrested in Nebraska for endeavouring to attend 
funeral ceremonies in South Dakota for a member of the American Indian 
Movement killed at Wounded Knee.) In this and many other cases, I served as 
Co-counsel to the National Native American Rights Committee for the National 
Office of the American Civil Liberties Union and as one of the Counsel in the 
United States Supreme Court case of MANCARI v MORTON (establishing the 
constitutionality of the preferential hiring of Native Americans by the 
National Bureau of Indian Affairs). 

10. After attending Harvard Divinity School, I served as General Counsel to 
the United States Jesuit Headquarters* Office of Social Ministry in 
Washington, D.C., in which capacity 1 served as National Chairman of the 
Washington Inter-religious Staff Council's Task Force on Civil Rights and also 
as the National Chairman of the Washington Inter-religious Staff Council's 
Task Force on Criminal Justice, In this latter capacity, I served as the 
primary Washington, D.C., lobbyist for the national religious community in 
opposing the passage of Senate Bill One, the draconian Nixon-Mitchell Federal 
Criminal Code. 

In this capacity I also chaired the Civil Liberties and Religious 
Community Briefing for United States Attorney General Griffin Bell in 1977. 

11. Between 1976 and 1986, I served as Chief Counsel in the major 
cnvironmenta; and civil rights case of KAREN G. SILKWOOD v THE KERR McGEE 

12. Since 1980, I have served as General Counsel and Chief of Litigation for 
the Christie Institute, a 501 (c)(3) public interest law firm and intcrfaith 
public policy center in Washington, D.C., serving as Chief Counsel in such 


CORPORATION, (successfully enjoining the General Public Utility Corporation 

from venting radioactive materials from the damaged Three Mile Island nuclear 

plant into the surrounding environment and compelling the corporation to 

undertake court-approved clean-up methods); the successful first degree murder 

defense of Mayor Eddie Carthan, the first elected black mayor in the 

Mississippi Delta since the Civil War; and the winning of the dismissal of all 

criminal charges against the staff of Catholic Bishop John Fitzpatrick of 

Brownsville, Texas, who had engaged in aiding Salvadoran refugees in their 

effort to obtain political asylum in the United Slates in the case of UNITED 



The iDYestigation Begins 

13. During the course of investigating the case of UNITED STATES v STACEY 
MERKT, I was contacted, in March of 1984, in Brownsville, Texas, by a 
Protestant minister. Source #1, and was informed by this Protestant minister, 

that he had been contacted by an FBI field agent in the Brownsville area. 
Source #2, and had been informed by this FBI agent that this agent had been 
instructed by a superior in the United States Department of Justice, Source 
#3, that undocumented Central American refugees being transported into the 
United States by members of the Catholic Church participating in the Sanctuary 
Movement included "known communist terrorists" who constituted "a potential 
threat to the national security of the United States", in that such persons 
were potential participants in "military cadres" to be launched against United 
States military installations, domestic communications centers and domestic 
water resource systems "in the event that President Reagan had to initiate 
a direct military action by US forces into Central America, either into El 
Salvador or into Nicaragua." This Protestant minister, who was reported to me 
by the professional religious personnel of Catholic Bishop John Fitzpatrick to 
be an honest and trustworthy source of information based upon their direct 
experience with him, informed me that he had been warned by this FBI field 
agent - whom the Protestant minister, in turn, knew to be an honest and 
trustworthy source of information to avoid any contact with such 
undocumented Central American refugees being aided by the Catholic Church 
participants in the Sanctuary Movement, if the minister wanted to avoid being 
caught up in trouble, in the event that President Reagan was forced to 
undertake military action in Central America. 

14. Being troubled by this report from an honest and trustworthy source, 
after I completed the Preliminary Hearing for Stacey Mcrkt before the Federal 
Magistrate in Brownsville, Texas, I returned to my office in Washington, D.C., 
and began a Preliminary Investigation to ascertain the source of this 
unfounded accusation against my church and against the members of the 
community of undocumented Central American aliens as I had come to know them. 

15. In undertaking this Preliminary Investigation, I reached out to several 
experienced and trustworthy professional investigators and professional 
investigative journalists whom I was certain had trustworthy sources who could 
locate the origin of this accusation. Among these investigators were: 

SOURCE #4, a licensed, professional private investigator who is the 
President of his State Association of Private Investigators, a member of 
his Governor's Private Security Advisory Group in his state, a former 
federal agent with a decade of experience working with members of the 
military intelligence community, the FBI, the Central Intelligence 
Agency, the US Customs Department, the DEA and various Slate Bureaus of 
Criminal Investigation; 

SOURCE #5, a professional research specialist for major national 
television networks, newspapers, and law firms, and former Professional 
Staff Member for a Committee of the United States House of 
Representatives involved in investigations relating to Intelligence 
Community and FBI abuses of citizens' rights; 

SOURCE #6, a professional investigative journalist previously employed 


as a staff investigator for syndicated columnist Jack Anderson, a staff 
member of the Washington, D.C.-based investigative journalist 
organization The Center For Investigative Journalism and a staff 
investigative journalist for CBS Evening News; and 

SOURCE #7, a former reporter with one of our nation's largest newspapers, 
a reporter for a national wire service and a staff investigative reporter 
for one of the national television networks. 

16. At the end of March of 1984, I communicated to Sources #4. #5, #6, and #7 
the information communicated to me earlier in March by Protestant Minister 
Source #1 and I asked them to ascertain for me the source of this accusation 

that the Catholic Church participants in the Sanctuary Movement were somehow 
involved in smuggling into the United States "known communist terrorists" who 
planned to form themselves, once inside the United States, into "military 
cadres" to undertake the launching of military assaults against U.S. military 
installations, domestic communication centers and domestic water resource 
systems - in the event that President Reagan deemed it necessary to initiate 
direct military action by U.S. forces in Central America, cither in El 
Salvador or in Nicaragua. 

17. During the second week of April of 1984, I was informed by Source #4 that 
President Ronald Reagan had, on April 6, 1984, issued National Security 
Decision Directive #52 authorizing then Federal Emergency Management Agency 
Director Louis O. Giuffrida and his Deputy Frank Salcedo to undertake a 

secret, nation-wide, "readiness exercise" code-named "REX 84". This exercise 
was to test the "readiness" of the Federal Emergency Management Agency to 
exercise civilian supervisory authority over defense department personnel, the 
personnel of all 50 State National Guard units and numerous, state-based 
"State Defense Force" units (which were to be established, at the behest of 
FEMA, by state legislative enactments) - in the event that President Reagan 
chose to declare a "State of Domestic National Emergency" concurrent with the 
launching of a direct United States military operation into Central America. 
This military operation was to be code-named "Operation Night-Train." 

According to Source #4, the "mission" of the FEMA operation to be tested 
pursuant to this REX 84 readiness exercise was two-fold. First, the Federal 
Emergency Management Agency (after "deputizing" all DOD personnel and State 
National Grand personnel - ostensibly so as to make such personnel 
"civilians," and to, thereby, avoid violating the Congressionally enacted 
Posse Comitatus Act^ would undertake to test its ability to seek out, and to 
take into custody, some 400,000 undocumented Central American aliens 
throughout the United States and, then, to intern said Central American aliens 
m ten military detention centers, to be established during this REX 84 

1 This Act of Congress forbids the use of any military 
personnel, such as DOD or National Guard personnel for domestic 
law enforcement purposes. 

readiness exercise at ten U.S. military bases throughout the United States.^ 
These undocumented Central American aliens were to be held at these detention 
centers during any real such Presidentially deemed State of Domestic National 
Emergency, without the right of Habeas Corpus, until President Reagan declared 
the State of National Emergency to be at an end. 

The second "mission" of the FEMA operation to be tested pursuant to this 
REX 84 readiness exercise was the distribution by FEMA, from U.S. military 
bases under the supervision of the United Slates Department of Defense, 
through the State National Guard Units, down into the hands of the civilian, 
state-legislature-created State Defense Forces -- of hundreds of tons of small 
arms and ammunition, ostensibly to be used by their civilian domestic law 
enforcement "deputies" to enforce domestic laws, during the pending of the 
Presidentially declared State of National Emergency. 

18. The interest of the Christie Institute focused primarily on the first of 
the two "missions" assigned to FEMA by this April 6, 1984 Presidential 
National Security Decision Directive. This first mission was of direct 
inimediate, interest to our law office in attempting to evaluate the "state of 
mind" and attitude of the Justice Department personnel who were to be 
"fielded" against us in the prosecution of the Sanctuary Movement personnel we 
were retained by the Catholic Church to defend in Texas. 

19. Upon learning of the existence of this REX 84 readiness exercise, I 
reached out, through Sources #4, #5, #6, and #7 to find an "inside source" at 
FEMA to either confirm or deny the intelligence information conveyed to me by 
Source #4 regarding the planned readiness exercises named REX 84. 

20. During the third week of April of 1984, Source #7 obtained for me an 
introduction to Source #8 - a member of the Legal Division of the Federal 
Emergency Management Agency, the office headed up by FEMA General Counsel 
George Delt. 

21. Source #8, who was known by Source #7 to be an honest and trustworthy 
source of information based upon Source #7's direct experience with him, was 
shocked that I had such accurate information concerning the content of 
Presidential National Security Decision Directive #52, but he expressly 
confirmed the accuracy of the intelligence report given to me by Source #4 
concerning the two-fold mission of REX 84. 

Source #8 expressed directly to me a high degree of fear and anxiety 

2 These ten detention camps were to be located at: 
(1) Fort Drum, New York; (2) Indiantown Gap Military Reservation, 
Annvillc, Pennsylvania; (3) Fort A. P. Hill outside of the 
District of Columbia in Virginia; (4) Fort Benning, Georgia; (5) 
Eglin Air Force Base in Florida; (6) Camp Krome, Florida (this 
base to serve as the jointly FEMA-INS Administration 
Interrogation Center) (7) Ft. Chaffee, Arkansas; (8) Fort 
Huachuca, Arizona - which was also to serve as the U.S. based 
ground communication center for Operation Night-train; (9) 
Vandenberg Air Force Base in California and one outside of 
Oakdalc, California. 


about the legality of what was being planned by FEMA General Counsel George 
Jell, FEMA Director Louis O. Giuffrida and FEMA Deputy Director Frank Salccdo. 
Source #8 reported to me that he had never before seen inside FEMA such an 
intense level of security concerning any program. Source #8 reported to me 
that FEMA General Counsel George Jett had ordered the installation of a 
special metal security door into the hallway on the fifth floor of the FEMA 
building in Washington, D.C. behind which door all of the planning for REX 
84 was being conducted. Indeed, Source #8 reported to me that even long- 
standing employees of the civil defense division of the Federal Executive 
Department possessing the highest possible security clearances were not being 
allowed through the newly-installed metal security door on the fifth floor of 
the FEMA building to have access to the planning of REX 84. Source #8 
reported that only FEMA Director Louis O. Giuffrida, his Deputy Director Frank 
Salccdo, FEMA General Counsel George Jett - and a few other men whom Source 
#8 noticed all wore a small red Christian cross, or crucifix pin, on the lapel 
of their suits - were even allowed through the metal security doors on the 
fifth floor of the FEMA building to have access to REX 84 information. 

Through a Source #9, I was able to obtain a series of Federal documents 
from inside FEMA which tend to confirm the above-reported description of the 
FEMA activities reported to mc during April of 1984. 

22. In early May of 1984, I was supplied by Source #4 with a number of 
documents describing, in some detail, a project supervised by then Special 
Assistant California State Attorney General Edwin Meese code-named "Project 
Cable Splicer". This project, undertaken by Edwin Meese, under the direction 
of then California Governor Ronald Reagan, took, then California Organized 
Crime Training Institute Commandant, Louise O. Giuffrida from his post in San 
Luis Obispo and made him the Commanding General of the California State 
National Guard. At the California Organized Crime Training Institute, 
Commandant Louis Giuffrida had been the Instructor in Civil Disorder Control. 
As Commanding General of the California State National Guard, Louis Giuffrida 
coordinated Project Cable Splicer for Special Assistant Attorney General Edwin 
Meese and Governor Ronald Reagan. 

Project Cable-Splicer was a special "war-games" readiness exercise 
1 pursuant to which Governor Reagan, Special Assistant Attorney General Edwin 

Meese and California State National Guard Commander Giuffrida could, together, 
I establish an effective state of state-wide martial law "in the event that 

I forces of radical black nationalism joined forces, inside the State of 

California, with the anti-Vietnam forces to challenge the established 
authority of the State." Project Cable Splicer was part of a larger program, 
code-named "Project Garden Plot" — which was a nation-wide war-games scenario 
prepared by then President Richard M. Nixon and his Attorney General John 
' Mitchell designed to establish a nation-wide state of martial law if Richard 

! Nixon's "political enemies" required him to declare a State of National 

j Emergency. 




"State Defense Forces" and a "Guns for Contras" Scam 

23. In mid-May of 1984, I was informed by Source #10. who was a professional 
journalist in New Orleans, Louisiana, that he had learned that the State 
Legislatures of Louisiana, Alabama and Texas had sometime around April 1984 or 
May 1984 each passed legislation establishing units known as '^State Defense 
Forces". Source #10 informed me that he was extremely concerned about this 
because the only people in Louisiana, Alabama or Texas who seemed to have 
heard of the passage of these statutes and who were, therefore, signing up 

to join these State Defense Forces were ultra right-wing para-military 
"survivalist-types", or "soldiers-of-fortunc-types", who were being advised to 
sign up for these State Defense Force units at weekend Survivalist Training 
Centers or ultra-right "war-game** schools. 

Source #10 informed me that this concern on his part had caused him to 
undertake an investigation to ascertain what was going on regarding the State 
Defense Force units in Alabama, Louisiana and Texas. Source #10 informed me 
that he had discovered that a group of men in Texas who had all signed up for 
the Texas units had been expelled by the Texas National Guard for being too 
radically right wing. This investigation led him to a Louisiana State 
National Guard Colonel, Source #11. Source #10 informed me that this 
Louisiana State National Guard Colonel had informed Source #10 that the State 
Defense Force unit in Louisiana was - in the near future - (this being in 
May of 1984) going to be receiving a large quantity of small arms and 
ammunition "in some kind of war game activity" supervised by the Federal 
government - but that the State Defense Force in Louisiana "was only going to 
have to give back half of the arms and ammunition received in the war-games. 
The half which were left with them were going to be smuggled out of the 
country to the Contras in Central America." This was to be achieved, 
according to the Colonel, by re-valuing the weapons, while in the field, from 
"manufacturer's" value to "replacement value", and then collecting the same 
dollar value, as was originally distributed at the outset of the war-game. 

Source #10 informed me that this Colonel had been proven, repeatedly, to 
be a reliable source of accurate information, and that the arms and ammunition 
which were to be left in the hands of the Louisiana State Defense Force Units 
were to be secretly transported to a Louisiana warehouse owned or supervised 
by a Louisiana state legislator (who had been active in obtaining the passage 
of the State Defense Force statute). This legislator's name was "Woody" 
Jenkins. The Colonel reported that from that point, the arms and ammunition 
would be airlifted (mixed in with "humanitarian" aid for the Contras in 
Central America) to Central America and given to the Contras -- "because the 
liberals in Congress had cut off the Freedom Fighters when the CIA got caught 
mining the harbors in Nicaragua". 

24. My own investigations revealed the existence of one "Woody" Jenkins in 
Louisiana, a man who was a Louisiana State Legislator of ultra right-wing 
political persuasion, who was running an allegedly "humanitarian aid" airlift 
to the Contras known as "Friends of the Americas." 

25. I informed Sources #4, #5, #6, and #7 of the information communicated to 
me by Source #10 and asked them to undertake inquiries to ascertain if any 
similar activity was under way in either Texas or Alabama. 


26. I was immediately informed by Source #7 that he w«s aware of a similar 
type of operation functioning in the state of Alabama. Source #7 told me the 
following information: 

American Mercenaries and the Contras 

26.1. That immediately prior to the Christmas holiday of 1983, Source #7 
had been contacted by a fellow professional journalist. Source #12, who 
had just returned home from a trip to Miami, Florida, where she had 
learned of the location of a Contra military training camp in the 
vicinity of Miami. She had learned that, in this camp, men were being 
trained on United States soil to undertake direct military attacks upon 

the citizenry and econonaic infrastructure of Nicaragua. Source #12 
informed Source #7 of the location of this Contra training base near 
Miami and suggested that Source #7 undertake a trip to this Miami area 
Contra training camp to interview the men training persons there and the 
men being trained. 

26.2. Source #7 traveled to the location described to him by Source #12 
in the vicinity of Miami, Florida over the Christmas holiday of 1983 and 
found the Contra military training camp there, exactly as described to 
him by Source #12. 

26.3. Source #7, being fluent in both English and Spanish, interviewed 
men doing the military training of Contras at this Miami vicinity base 
and the men receiving the Contra training over the 1983 Christmas holiday 

A Honduran Meeting 

26.4. During these interviews. Source #7 learned that there was a 
contingent of former U.S. military personnel and active members of 
various U.S. State National Guard units who were planning to organize an 
unlawful, American-based, para-military organization to train, equip, and 
finance - from U.S. soil - and actively to participate in military 

field operations with the Contra forces in Central America against the 
U.S.-recognized Government of Nicaragua. During these interviews, held 
at the Miami area Contra military training base by Source #7 during the 
1983 Christmas holidays, Source #7 learned that the U.S. citizens who 
were organizing this unlawful American-based para-military organization 
to be established to aid the Contras from U.S. soil, were planning to 
hold a meeting at a particular hotel located in Tegucigalpa, Honduras in 
January of 1984 to finalize specific plans for obtaining U.S. military 
equipment for and providing other federally prohibited aid to the Contra 

26.5. Having failed to obtain permission from his United States based 
newspaper to attend and to report on, this planned January 1984 meeting 
of U.S. citizens at the Tegucigalpa hotel, Source #7 took a temporary 
leave of absence from his newspaper and financed his own trip to 


Tegucigalpa in January of 1984. 

26.6. In January of 1984, Source #7 travelled to Tegucigalpa, Honduras, 
and registered at the hotel described to him in interviews held at the 
Miami Contra training base during the Christmas holidays of 1983. While 
sitting in this hotel lobby, Source #7 observed numerous white adult male 
U.S. citizens speaking English and dressed in various forms of camouflage 
and war surplus U.S. military garb. 

26.7. During his prolonged period of observation in this hotel lobby in 
Tegucigalpa, Honduras, during January of 1984, Source #7 struck up a 
conversation with a white adult male United States citizen who was a 
participant in the para-military group meeting transpiring at the hotel. 
Source #7 informed this person that Source #7 was an American writer 
interested in understanding and publicly reporting on what was 
transpiring at this Honduran hotel. 

26.8. The white adult U.S. male with whom Source #7 had struck up this 
relationship was Thomas Posey - the Defendant in the present Federal 
civil lawsuit. 

26.9. During these January, 1984 conversations at the Tegucigalpa Hotel 
with Source #7, Defendant Thomas Posey described, in some detail, the 
entirely illegal plan of action being developed by the U.S. participants 

in the January 1984 meetings in Honduras. Defendant Posey described how 
he and his associates were organizing an American-based group - which 
was named the Civilian Military Assistance organization - the mission of 
which was to recruit, train, finance, supply and to launch, from United 
States soil, a foreign military expeditionary force, consisting of U.S. 
citizens who were former members of the United States armed forces and 
present members of various state National Guard units and anti-communist 
Cubans, Nicaraguans and other Central Americans who wished to undertake 
direct military action to overthrow the socialist government in 

During these January, 1984 conversations with Source #7, Defendant 
Posey expressed his opposition to the public policy and laws of the 
United States Congress regarding Nicaragua, stating that Defendant Posey 
and his Civilian Military Assistance organization were going to organize 
and prosecute the war against the government of Nicaragua which the 
United States Congress did not have the political conviction to allow the 
official United States military to prosecute. 

26.10. Between January of 1984 and mid-May of 1984, Defendant Posey had 
several conversations with Source #7 during which conversations Defendant 
Posey openly admitted his unlawful activities supplying military 
equipment and explosives to Contra military and terrorist units in both 
Honduras and Costa Rica -- with the express understanding and intention 
that this military equipment would be used against the unarmed civilian 
population inside Nicaragua to terrorize the people and to destabilize 

the government of Nicaragua. Indeed Defendant Posey openly solicited 
Source #7 to prepare and to publish, within the United States, reports of 
Defendant Posey's convictions and activities so as to assist Defendant 


Posey in his recruitment of U.S.- based contra supporters and in his 
raising of money. 

26.11. Source #7 personally attended Executive Committee sessions of the 
leadership of the Civilian Military Assistance organization and 
personally observed and heard planning sessions in which overtly criminal 
operations were planned and agreed to by Defendant Posey, between January 
and May of 1984. These activities Source #7 reported to me in May of 
1984, requesting my analysis of the unlawful nature of the activities of 
Defendant Posey and his associates in the Civilian Military Assistance 
organization. I provided this legal analysis, pointing out that their 
activities constituted a direct criminal violation of numerous federal 
criminal statutes, including the Federal Neutrality Act, the Federal 
Arms Export Control Act, various Federal Firearms and Explosives Statues 
and other Federal and State laws. 

An American Mercenary's Diary 

27. Through Source #7, I was introduced to Source #13, a direct participant 
in the high-level planning and execution of the criminal conspiracy of 
Defendant Posey and his associates in the Civilian Military Assistance 

28. Source #13, prior to the filing of the Civil Complaint in this case, 
described for me, in detail, the Federal Criminal activities of Defendant 
Thomas Posey regarding the obtaining of allegedly "surplus" U.S. military 
equipment from the 20th Special Forces Unit of the United States Army in 
Alabama and the obtaining of access to an allegedly "surplus" U.S. Armed 
Forces airplane in New Jersey in which to transport this material from U.S. 
territory, via Ilopango Air Base in El Salvador to Costa Rica, Honduras, and 
Nicaragua. Source #13 described personally seeing crates of U.S. military 
equipment (clearly marked as such) stacked in the private garage of Defendant 
Thomas Posey awaiting transfer to the state of Florida, where the military 
material was to be secretly flown to Ilopango Air Force Base for transhipment 
to contra forces in Costa Rica and Nicaragua. 

29. Indeed, Source #13 personally informed me of the existence of his hand- 
written daily diary - into which he had made regular contemporaneous daily 
entries from a period in 1983 all the way to 1986. He described certain 
events memorialized in this diary - and 1 have personally reviewed a xerox 
copy of this diary. Details taken from Source #13's statements to me and from 
his diary arc set forth below in this Affidavit. 

30. During my conversations with Source #13, he informed me that he was aware 
of the identity of several men who had personally participated in the 
transporting, loading, and flight of forbidden military equipment from the 

State of Florida, to Ilopango Air Force Base in El Salvador, and from there, 
onto the Costa Rican ranch of an American by the name of John Hull. This is 
the same John Hull who is named as a Defendant in the present Federal Civil 

The men named by Source #13 are Source #14, one Jesus Garcia; Source #15, 


one Steven Carr; Source #16, one Peter Glibbcry; Source #17, one Jose Cotinc; 
Source #18, one Alan Saum; and Source #19, another individual with direct 
personal knowledge of these illegal weapons and explosives transactions. 

31. Either I, or one of my investigators or associates, have personally 
interviewed each of Sources #13, #14, #15, #16, #17, #18. and #19 or they 
have been directly interviewed by Source #20, Attorney John Mattes, the 
Assistant Federal Public Defender in the United States District for Southern 
Florida or his professional investigator. Source #21. The content of these 
interviews have been communicated to me. These interviews set forth the 
first direct, first-hand, knowledge of Sources #13, #14, #15, #16, #17, #18, 

and #19 of the participation of Defendants Thomas Posey, John Hull and Bruce 
Jones in the Federal Criminal Conspiracy to violate the Federal Neutrality Act 
and the Federal Arms Export Control Act described in the Plaintiffs' Amended 
Complaint. These facts, and the specific sources of the these facts will be 
set forth below. 

32. In June of 1984, I left Washington, D.C, to travel to the United States 
District for Southern Texas, Brownsville Division, where I served as Chief 
Trial Counsel in the case of United States v. Stacev Lvnn Merkt. et al. 

A White House Connection: North, Posey and Owen 

33. Upon returning to Washington, D.C, in late June of 1984, I was contacted 
by Source #7 and was asked to meet with him. In this meeting. Source #7 
informed me that, during the month of June of 1984, Source #7 had been 
contacted by Defendant Thomas Posey, who had arrived in Washington, D.C 
Source #7 stated that he had met with Thomas Posey, in Washington, D.C, in 
June of 1984, and that Defendant Thomas Posey had physically introduced Source 
#7 to one Robert Owen -- the same Robert Owen who is named as a Defendant in 
the present Federal Civil Lawsuit. 

I 34. Source #7 stated to me, in June of 1984, that Source #7 had met with 

Defendant Robert Owen and Defendant Thomas Posey in a public park in 
Washington. D.C, in June of 1984 and that Defendant Robert Owen, at that 
time, stated to Source #7 that Robert Owen was a purely private citizen who 
was acting solely in his purely private capacity to meet with the military and 
political leadership of the Contras to communicate to them political advice as 
well as to advise them in regard to what military equipment they might need to 
carry out their military operation against the Nicaraguan Government. During 
this June, 1984 public park meeting with Source #7, Defendant Robert Owen -Iso 
stated that Defendant Owen was "taking orders" for weapons, military equipment 
and explosives from the Contra military commanders in Central America and 
seeing to it that their orders were filled and that the material was, in fact, 
supplied to the Contras in Central America. 

35. Then, during this same public park meeting with Source #7 in June of 
1984, Defendant Robert Owen expressly stated to Source #7 that Defendant 
Robert Owen was "the personal representative to the Contras of Marine Corps. 
Lt. Colonel Oliver North, the Deputy Director of the United States National 
Security Council for Political-Military Liaison" and that Defendant Owen was 


acting privately to meet with the Contra Field Commanders as the "go-between" 
for Lt. Colonel North - because Lt. Colonel North could not meet directly 
with the Contra leaders, in light of the United States Congressional ban 
against direct or indirect support being provided to the Contras by the 
Executive Branch of the United State government. 

At this meeting with Source #7 in June of 1984, Defendant Robert Owen 
told Source #7 that Lt. Colonel North wanted Source #7 to travel to Costa Rica 
and there to attend, and then to file a published report concerning, a secret 
meeting which was to be held in Costa Rica among disparate Contra factional 
leaders seeking to form a group to be called UNO the United Nicaraguan 
Opposition. This was to be a coalition group of heretofore contesting Contra 
military leaders whom Colonel North wanted to unify, in order to increase the 
chances of the Administration to win Congressional approval to re-commence 
diri^jct CIA funding and sponsorship of the anti-communist Contra forces. 

36. Source #7 was surprised by the revelation made to him by Defendant Robert 
Owen - so he sought me out immediately upon my return from Texas to discuss 
the legal implications of what he had learned. 

37. After my late June 1984 discussion with Source #7, I prepared a legal 
opinion for Source #7. This legal opinion was provided to Source #7, a 
professional journalist, with a view towards establishing a full scale 
investigation to inquire into - and to expose -- what was going on out of the 
White House office of Lt. Colonel Oliver North and in the states of Florida, 
Alabama, and Texas among these private para-military organizations and Slate 
National Guard forces. 

38. During July of 1984, I traveled to the United States Middle District of 
North Carolina to conduct the depositions of members of the Ku Klux Klan, the 
American Nazi Party, the Federal Bureau of Alcohol, Tobacco and Firearms oC 
the United States Department of the Treasury and the Greensboro City Police 
Department who had participated in the planning and execution of the armed 
assault upon the Workers Viewpoint Organization Anti-Klan March in which 
marchers were murdered in 1979. I was,thcreforc, absent from Washington until 
the end of 1984. 

39. Indeed, throughout the first half of 1985, I was engaged full-time as 
Chief Counsel in the prosecution of the federal civil case of Waller v. 
Butkavitc h. et al. in North Carolina. 

Orricial, Covert U.S. Government Aid to Contras 

40. Upon my return to Washington, D.C, in the second half of 1985, I met 
with my sources involved in the Posey-HuII investigation - and I was informed 
that an American ABC television cameraman had been very seriously injured in a 
May, 1984 terrorist bombing attack of the public press conference called by 
former Sandinisia military commander Eden Pastora to denounce Adolfo Calero, 
Calero*s FDN Contra organization, and the American Central Intelligence Agency 
for trying to destroy Pastorals independent and nationalist Nicaraguan anti- 
Sandinista force based in Costa Rica. I was informed by my sources that this 
American ABC television cameraman had discovered that he had been injured in 


1 t 



an attack planned by Defendant John Hull and a Costa Rican-based anti- 
Sandinista terrorist group supplied with C-4 explosives by Defendants Thomas 
Posey» John Hull and Bruce Jones. 

41. I expressed interest, on behalf of the Christie Institute, in hearing 
from this ABC television cameraman named Tony Avirgan, and I was, soon 
thereafter, contacted by Mr. Avirgan. 

42. In my 1985 conversations with Tony Avirgan, with his fellow journalist 
wife Martha Honey and with sources who were in direct contact with them 
I learned the following facts - the particular sources for which will be 
described later in this Affidavit. 

42.1. That on July 17, 1979, Nicaraguan Dictator Anastasio Somoza 
fled Nicaragua in the face of virtual universal condemnation of his 
dictatorial and unjust regime, his unjust conduct having resulted, in 
early 1979, in the total cut-off of all military assistance to his regime 
by United States President Jimmy Carter under the dictates of the 
Congressional Harkin Amendment (prohibiting any U.S. military aid to any 
regime found to have systematically violated the human rights of its own 

42.2. Somehow, after the U.S. cut-off of military aid. Dictator 
Somoza had found another source of U.S. military equipment which enabled 
him to remain in office until July 17, 1979. 

42.3. After his flight from Nicaragua, in July of 1979, former 
Dictator Somoza set up several of his dreaded National Guard Generals in 
Honduras, the neighboring country of Nicaragua, and proceeded to 
supervise them in the mounting of a Xontra" military operation against 
the 1979-officially-U.S.-recognized government of Nicaragua. No one 
seemed to know from whence these "Contra" forces (as they came to be 
called) were receiving their financing or their military supplies. 

42.4. This "Contra" operation functioned under the direction of 
former Dictator Somoza himself until he was assassinated in September of 
1980 in Paraguay. The operation was, then, taken over and run by his 
former generals from 1980 to 1981. 

Still, no one knew who was funding or supplying this Contra force 
with military equipment. 

42.5. When Ronald Reagan took office as President of the United 
States in January of 1981, a series of White House meetings took place - 

attended by White House Chief of Staff Edwin Mecse; White House National 
Security Advisor Richard Allen; United States CIA Director William Casey- 
United States Vice President (and Chairman of the National Security 
Council Task Force on Terrorism) George Bush and President Ronald 
Reagan himself. In these meetings, it was discussed, and later agreed 
that the United States CIA, under the direction of CIA Director Willikm 
Casey, would "take over" the secret funding and military supply of the 
Honduran-bascd, "Contra" forces. 


Reagan Orders the CIA to Back the Contra* 

42.6 ^° o*" '981. President Ronald Reagan signed a clas.ifirH 

Nauonal Secur.ty Decision Directive expressly autho?izing'and dir c 

? 5':"'"' !"'«"i8en« Agency Director William Casey to ' 

undertake the direct financing, training and military supply of the 
Honduran-based Contra forces - but directing CIA Director Wil .am Casev 
^oo^lv o7 '"dership that such CIA funding and ' 

L conl '0 Contras was to be conditioned upon 

ni ,, mil. ary commanders organizing themselves into a coherent and un.fied coal.tion through which a centralized system of 
Agency"* ^ ""'"^ ""^ conducted by the Central Intelligence 

DirLnr WT^" ""'''^'^ Intelligence Agency 

Casey assigned to CIA agent Vincent M Cannistraro tL 

?i„tr/> A^""""^' ^'"^ '"PP'y °^ ^""'^^ ''"d -"fi'^^y equipment to the 
Central American Contras. This operation began in June of 1981. 

"^ LtK IT Jc" Proceeded, apace, throughout 1981 and into 1982 

tTe States President Ronald Reagan repeatedly publicly denying^Tf """^ ^'"^ °' involvement in supplying^ 

training or funding the so-called Contra forces in Central America 

m,hii..« ^J'^u ''^"^ investigations and U.S. Congressional inquiries 
publ cly exposed the fact that the White House was secretly funding and 
supplying the Contras. President Reagan admitted the existence of "mTnor" 
assistance to the Contras by the CIA - which assistance. President 

fhe funntr/f' • '""'"'^ *° ''^'"^ Contra in "interdicting 

the supply of weapons and military equipment flowing from the Sandinista 
government of Nicaragua to the anti-government forces in El Salvado - 

rili?" . . c U.S press and Congressional members pressed the Executive 

?en^rT,;?,,n:,^rI^ ^"^8=^ gun shipments the 

orelri 1 r.l^p '^S^"^. ."'"Sncd CIA agent David McMichaels to 
M?MVK , Report establishing such traffic. When CIA agent David 
McMichaels reported that there was no evidence to support the conclu k)n 
that any such weapons trafficking existed from the Nicaragua n goveJnrnt 
ScMfcSS"""""' ^' ^^'^ fired'agen? 

ap,i„ vK^il^"* "^u"*"" '^'^ P"'"'<= position on the Contras 

E HonlVr'- ' "''T'i ^'-^ being authorized by the 

White House to support the Contras only to the degree necessary "to place 

uo'tntf ' °" the government of Nicaragua 'to reform itsel ' to 
BOvernmenX'^ 'u' P'"^^""**^ so<=i=ty. economy and form of 

fhev lerthl f/vnTr Nicaragua by the Sandinistas when 

tney led the revolution against Somoza." 

tl^ u. ^ ^"'•c^' States Central Intelligence Agency was 

c?vi?.a; hatbors''rf'L"''°"'- "^^'"^ P'="^ mice's ?n'the 

Con r,^ I^I ? I '^^".='8"a - and for passing out "manuals" to the 
Contras openly advocating the physical assassination of civilian 


government authorities inside Nicaragua to bring about the overthrow of 
that government. Both of these acts were violations of international 
law. President Reagan, therefore, finally publicly acknowledged that it 
was his objective to violently overthrow the officially-recognized 
government of Nicaragua, "to prevent the establishment in Latin America 
of a Soviet military base.** 

A Congressional ban on '^Direct or Indirect" Aid 

42.12. After a national and international uproar over the conduct of 

the American CIA, Congress began to draft a piece of legislation to order 
the cut-off of all military assistance - both direct and indirect -- by 
the United Stales Executive Department to the Central American Contras. 

The ''Privatization'' of the Contra War 

42.13. Upon learning of this plan of Congress, White House Chief of 
Staff Edwin Mcese. Vice President Bush, Central Intelligence Agency 
Director William Casey, National Security Advisor Robert McFarlane and 
NSC staff member Lt. Colonel Oliver North met and devised a method for 
intentionally circumventing this Congressional ban. 

42.14. In these meetings, this group decided to have Lt. Colonel 
Oliver North establish contact with the secret group of private 
individuals who had financed and supplied the military equipment to the 
Contras prior to June of 1981 and to notify them that the White House 
and the CIA would no longer be allowed to fund and supply the arms and 
military equipment to the Contras after March of 1984. 

In these meetings, this group also decided to have Lt. Colonel 
Oliver North establish contact with Gray & Company (a Washington, D.C.- 
based public relations and advertising organization) and to have Rob Owen 
of that organization set up a private citizen-operated Contra support 
group to publicly solicit funds and assistance for the Contras after the 
up-coming prohibition of White House aid to the Contras. This operation 
would give a feasible explanation for the source of the funding and 
supply of the Contras so that Congress and the press would not 
conclude that the CIA was still supplying the Contras. 

This public organization was set up by Rob Owen by contacting 
General John K. Singlaub - who, in turn, set up the United States 
Council on World Freedom and began publicly raising funds for the 

In fact. General Singlaub raised money inside the United 
States which was directed, by him, to be deposited by 
contributors in a Grand Cayman bank for use in the purchasing of 
weapons and explosives for the Contras. Singlaub also travelled 
to Central America with Robert K. Brown and personally 
facilitated providing one John Henry "I.W." Harper to the 
Contras, who trained Contras in the construction of C-4 anti- 


The Hull Terror-Drug Operation: A Defector's Story 

43. From my late 1985 conversations with Tony Avirgan, Martha Honey and their 
sources, as well as from my direct personal conversations with one Carlos 
Rojas Chinchilla, Source #25, I next learned the following facts^: 

personnel bombs exactly like the one which was used to bomb the 
La Penca press conference. In fact, Plaintiffs' Counsel has been 
informed by Source #24 that Defendant Singlaub and Robert K. 
Brown directly provided Harper to Defendant Amac Galil who helped 
Defendant Galil construct the very C-4 bomb which Galil used to 
blow up the May 1984 Eden Pastora press conference. Source #24 
is a person with knowledge of the activities of Defendant 
Singlaub, Robert K. Brown and John Harper with the Contras. 

^ Prior to the La Penca bombing, Avirgan and Honey, in 
their capacity as professional journalists, had developed well 
placed sources within Eden Pastora's movement as well as Costa 
Rican government officials who had provided them with detailed 
information about the conflicts within ARDE and about CIA 
maneuvers to force Pastora to join with the Honduran-based contra 
movement, the Nicaraguan Democratic Alliance (FDN). They had 
written articles for the New York Times and London Times and 
worked on news reports for ABC television and radio detailing the 
CIA pressures. They were aware beforehand that Pastora was 
calling the La Penca press conference to denounce the CIA 
maneuvers against him and to declare his refusal to join with the 
FDN. Honey did not attend the La Penca press conference because 
she was writing a story, which appeared on the front page of the 
New York Times the day after the bombing, stating that the CIA 
had given Pastora a 30 day ultimatum to join with the FDN and 
that if he refused he would face unspecified consequences. 

Immediately after the bombing, while Avirgan was still 
recuperating. Honey was commissioned by the Committee to Protect 
Journalists and the Newspaper Guild to undertake a through 
investigation of who was responsible for the bombing. Avirgan 
joined the investigation in August, as did several other 
journalists based in Costa Rica. Over the next year, this team 
carried out several hundred interviews and learned the following 
information which was put into a report submitted to these two 

Almost immediately they learned from ARDE officials and 
contacts in Miami about a group of right-wing Cubans working with 
the Costa Rican-based contras and involved in several attempts to 
split contra commanders away from Eden Pastora. They were told 
one of the group's leaders, Felipe Vidal, had discussed the need 
to eliminate Pastora with a bomb and that Cubans in Miami had 
discussed before La Penca eliminating Pastora and afterwards had 
boasted to associates about carrying out the plot. Avirgan and 


43.1. That in March of 1985, Carlos Rojas Chinchilla, a gainfully- 
employed professional carpenter residing in the city of San Jose, Costn 
Rica, was present at a public restaurant and bar named the Rendezvous Bar 
located a few blocks from the United States Embassy in Costa Rica. 

43.2. While present in this bar, after finishing work, Carlos Rojas 
Chinchilla personally witnessed three men come into the Rendezvous Bar. 
He saw them stop in the doorway for a short conversation and then Carlos 
saw two of the men leave the bar. The third man was left standing in the 
doorway. After a few moments of standing in the doorway, watching the 
two other men depart down the street in the direction of the U.S. 

Embassy, the man who had remained behind in the doorway of the bar turned 
and began surveying the persons present in the bar. 

43.3. This man's survey finally came to rest upon Carlos, and the man 
briskly walked from his watch at the doorway and moved into the bar to 
the table where Carlos sat. 

43.4. The man told Carlos that his name was David, Source #26, and 
that he had gotten himself involved in a situation from which he needed 
someone's assistance to escape. 

David explained to Carlos that David and his brother were 
Nicaraguans who had joined the Contra forces in Costa Rica to fight 
against the Sandinista government in Nicaragua. David explained that 
David had, somehow, come to be part of a Special Unit of the Contra 
forces in Costa Rica which made up a sort of "International Brigade** 
physically based on the ranch of an American rancher by the name of John 
Hull. David told Carlos that this American rancher was the supervisor of 
this Special Unit or International Brigade and that the group operated 
from John Hull's main ranch and other properties, some of which were 
located on the northern-most boundary of Costa Rica abutting the river 
which constitutes the southern border of Nicaragua. 

Honey developed, over a number of months, a close relationship 

with Felipe Vidal and from him and several of his associates, 

learned that these Cuban were involved in forming an 

"International Brigade" to provide military trainers and military 

supplies to the contras, that a numbers of the leaders were tied 

to the CIA, and that a number of the members had been involved in 

terrorist and drug trafficking activities. They also learned 

that John Hull, Bruce Jones and Rene Corbo were leaders of the 

Brigade and there were strong indications that Vidal, Hull, Jones 

and Corbo had been involved in La Penca. 

Avirgan and Honey and their colleagues also gathered 
information indicating that members of the FDN and ARDE as well 
as some Costa Rican governments officials had been involved in 
the planning, carrying out and covering up of the bombing. 

Avirgan and Honey also were told by security officials in 
several countries, contras, and people in Miami that the FDN was 
behind and had authorized and financed the bombing 


Cocaine and a Plan to Assassinate a U.S. Ambassador 

43.5. David told Carlos, in this early 1985 meeting, that this 
International Brigade supervised by John Hull had been directly 
responsible for the May 30, 1984 bombing of the Eden Pastora press 
conference - and that the same group was, at that very moment, actively 
engaged in going forward with a plan to carry out a terrorist bombing of 
the United States Embassy in San Jose, Costa Rica and a plan to 
assassinate the new United States Ambassador to Costa Rica, Lewis Tambs. 
David stated to Carlos that the two men with whom David had arrived at 
the bar were, at that moment, "casing** the U.S. Embassy down the street 

in preparation for the future bombing of the installation. 

David explained to Carlos that the International Brigade supervised 
by John Hull and housed on his ranch to the north of San Jose was 
directly involved in the trans-shipment of large quantities of Colombian 
cocaine from the airstrips on John Hull's farm (airstrips which had 
recently been lengthened and improved to accommodate aircraft arriving at 
John Hull's ranches with loads of military equipment, weapons, ammunition 
and explosives). Other sources informed the Plaintiffs that this cocaine 
came from one Jorge Ochoa and one Pablo Escobar, the two largest cocaine 
producers and exporters in Colombia - and that the cocaine was being 
moved from John HulTs ranch into the United States where it was sold, a 
portion of the profits going to John Hull and his International Brigade 
to help finance the guns, ammunition and explosives being used in their 
military effort against the government of Nicaragua. 

David told Carlos that in addition to bombing the Embassy, the 
International Brigade intended to kill a U.S. diplomat who he later 
identified as Ambassador Lewis Tambs. David told Carlos that the bombing 
and the assassination of Tambs would be made to look like the work of the 
Sandinista government of Nicaragua in an effort to instigate direct 
military action by the United States against Nicaragua. 

Other sources later told the Plaintiffs that the International 
Brigade was also aware that Pablo Escobar had put a $1,000,000 dollar 
"bounty" on the head of Ambassador Lewis Tambs. Escobar was reportedly 
infuriated at the efforts made by Tambs, when Tambs was U.S. Ambassador 
to Colombia, to obtain an extradition treaty between Colombia and the 
U.S. which would allow the extradition of Escobar and other cocaine 
traffickers to the U.S. for prosecution for drug smuggling. The 
International Brigade hoped to additionally collect the $1 million bounty 
to aid them in their purchase of military equipment for use in their 
military effort against Nicaragua. 

43.6. David told Carlos in this conversation that David did not want 
to participate in this International Brigade any longer — that he did 

not support the activities of the group directed against the U.S. Embassy 
and Ambassador Tambs and he did not support the activity of the group 
involved in drug smuggling to finance their operations. 

But David told Carlos that David needed help in escaping from the 
group that everyone in the group was watched by everyone else, as a 
precaution against dissention and revelation of their activities. David 
needed an "outside" person, someone who could help David and his brother 



(who was fighting elsewhere with the Contras), escape without observation 
by members of the International Brigade. David asked for Carlos' help. 

43.7. Carlos refused, pointing out to David that Carlos was a 
married man, with a wife and three children - and that Carlos lived in 
a small row house with his wife*s beauty shop on the ground floor, a 
place where any stranger, such as David or his brother would surely be 
noticed if they tried to hide there. 

43.8. David pleaded for Carlos to help and told Carlos to look for 
him around the Embassy or at a town in northern Costa Rica, if Carlos 
decided to help him. 

Then David was gone, as the two men with whom he had arrived 

43.9. Carlos went out of the bar after the men left and saw them 
enter a large, gray car, without any license plates, and depart. 

Carlos went to the home of his mother and informed her as to what 
had occurred and sought her advice. She directed him to stay out of it 
and to do nothing. 

In a move to enforce Costa Rica's official policy of neutrality 
towards Nicaragua, Costa Rican Rural National Guardsmen raided, in late 
April 1985, a contra camp located on property near the Nicaragua border 
managed by John Hull. They arrested nine Nicaraguan contras, five 
foreign mercenaries including two Americans, and seized significant 
amounts of guns, cannons, ammunition and explosives. This equipment 
included guns and military equipment smuggled from Florida's Ft. 
Lauderdale Hollywood Airport on March 6, 1985, by Sources #14. #15. #16 
and #17. and Defendants John Hull, Bruce Jones and Thomas Posey. 
Indeed, specific weapons expressly purchased and registered in the 
United States by Defendant Thomas Posey were seized by the Costa Rican 
Rural Guard on John Hull's ranch in early 1985, and are presently 
available as evidence. 

When Carlos Rojas Chinchilla learned of this Rural Guard action, 
he realized that the description of the ranch, the name of the owner of 
the ranch and the description of the man arrested and the equipment 
seized all matched, exactly, the description of the International 
Brigade described by David to Carlos in their early 1985 meeting at the 
Rendezvous Bar. 

This caused Carlos grave concern, since this ability of David to 
describe so exactly the characteristics, equipment and locale of the 
International Brigade arrested by the Costa Rican Rural Guard convinced 
him that David had communicated to him equally accurate information 
about the plans of the group to bomb the U.S. Embassy and to 
assassinate U.S. Ambassador Lewis Tambs. 

44, Following the arrest of the mercenaries on Hull's property, Carlos 
Rojas Chinchilla realized that David's story had some basis in fact. He 
sought the counsel of the only North American he knew, a woman neighbor 
married into a Costa Rican family friendly with his family. Carlos 
communicated the information to the members of this North American family, 


Sources #29, #30, and #31, which had been told to him by David. 

45. As it turned out, the daughter of this North American family. Source 
#31, knew the Plaintiffs Tony Avirgan and Martha Honey and, following her 
receipt of this information from Carlos, Source #31 contacted Tony Avirgan 
and Martha Honey and informed them of the content of the meeting between 
Carlos and David. 

46. Tony Avirgan and Martha Honey, through Source #31, contacted Carlos 
Rojas Chinchilla in 1985 and persuaded Carlos to attempt to reestablish 
contact with David. 

47. In 1985, Carlos did reestablish contact with David - and, at the 
request of Tony Avirgan and Martha Honey, Carlos met with David and asked 
David to explain, in detail, the information David possessed about the La 
Penca bombing, about the activities of the so-called "International Brigade" 

of Contra supporters operating from John Hull's Costa Rican ranch - and 
about what David knew about the future plans of this Brigade. 

48. In a series of meetings between David and Carlos held over the ensuing 
weeks, David shared with Carlos the information which follows - some of 
which was tape recorded by Carlos and some of which Carlos orally repeated 
to Tony Avirgan, Martha Honey and Source #31 immediately after his 
interviews with David.^ 

49. Both Tony Avirgan and Martha Honey spoke, by telephone, with David, 
confirming his existence, his name and his possession of the general 
information set forth below. But David would not meet directly with the 
journalists. However, Plaintiff Avirgan did physically see David at a 
distance, meeting with Carlos, on one occasion from which meeting Carlos 
returned and shared more information with the Plaintiffs which came from 

50. In his direct interviews with David, Carlos was given the following 
information - which fact Plaintiffs' Counsel has personally confirmed from 
direct interviews with Carlos. 

50.1. David told Carlos that David and his brother, who were 
Nicaraguan citizens, had grown disillusioned with the Sandinistas 
government in Nicaragua, and left Nicaragua and had joined the Contra 
forces based inside Costa Rica. 

50.2. David's brother was no longer with David, but was, rather, off 
fighting somewhere else with the Contras against the Nicaraguan 

50.3. David had somehow come to be assigned to a group of men made up 

Plaintiffs' Counsel is in possession of said tape recording and notes 
from these interviews with David. 


of Nicaraguan Contras» cx-patriot Cubans from Miami, foreign 
mercenaries, and soldier of fortune types who were based upon the 
cattle ranch and citrus farms owned or managed, directly on the Costa 
Rican side of the Costa Rican-Nicaraguan border, by a millionaire 
American rancher by the name of John Hull, the same John Hull named as 
a Defendant in this suit. 

50.4. Working with John Hull was another American rancher who owned a 
ranch near that of John Hull. This man*s name was Bruce Jones, and is 
the same Bruce Jones named by Plaintiffs as a Defendant in this suit. 

50.5. Both Hull and Jones had earlier been directly associated with 
agents of the American Central Intelligence Agency and had given over 
their ranches as ''staging areas" for the landing and off-loading of 
American CIA-supplied weapons and ammunition which were being supplied > 
by John Hull to the Contra forces based in Costa Rica and just across 

the border inside Nicaragua. This information came from sources other 
than David, prior to contact with David. 

50.6. David was a part of this "International Brigade" of Contras and 
mercenary Contra-supporters and shared the Contra desire to overthrow 
the Nicaraguan Sandinista government by military force. 

50.7. However, in 1983, one of the Costa Rican-based military 
commanders of the Contras, who was being supplied with military 
equipment by the American CIA through John Hull, one Eden Pastora, 
began to have difficulty with Hull and the CIA's man who was repeatedly 
on John Hull's ranch. This CIA man was one Duane "Dewey" Claridge. As 
a result, the CIA kept starting, and then stopping, the supply of arms 

to Eden Pastora. Hull and Dewey Claridge were angry with renegade 
Contra commander Pastora, because Pastora would neither accept 
supervision from American CIA personnel sent in to Costa Rica to 
provide "advice" to Pastora, nor would Pastora agree to integrate his 
Costa Rican-based Contra forces into a unified Contra command under the 
leadership of the Honduran-based FDN led by one Adolfo Calero and 
former Nicaragua dictator Anastasio Somoza's former National Guard 
generals. (This information came from sources other than David - 
prior to David's contact with Carlos as did the information in 50.8 
to 50.10 below.) 

50.8. In mid-1983, a number of Cuban-Americans from Miami arrived at 
John Hull's ranch and asked John Hull to arrange a meeting between 
these Cuban-Americans and representatives of Contra commander Eden 
Pastora with a view toward Pastora's agreeing to allow these Cuban- 
Americans to bring down to Costa Rica a number of their Miami-based 
Cuban-American associates to fight against the Sandinistas as part of 
Eden Pastora's ARDE forces. 

Contra Cocaine to the U.S. 

50.9. When this request of the Cuban-Americans was rejected by Pastora 



in May or June of 1983, two of these Cuban-Americans, one Felipe Vidal 
and one Rene Corbo began setting up a cocaine trans-shipment operation 
on John Hull's ranch. 

50.10. Felipe Vidal and Rene Corbo coordinated the landing of small 
planeloads of cocaine flying onto John Hull's ranch --and onto the 
numerous other ranches "managed" by John Hull which were adjacent to 
Hull's ranch along the Costa Rican border with Nicaragua. The cocaine 
on these planes came from one Jorge Ochoa and one Pablo Escobar - the 
two biggest cocaine producers and traffickers in Colombia. On John 
Hull's ranches, this Ochoa-Escobar cocaine was off-loaded and then 
trans-shipped up into the United States* going to Miami, New Orleans, 
and Memphis. 

50.11. David told Carlos that David was totally opposed to this 
cocaine smuggling. But he said that a portion of the income earned by 
John Hull, Felipe Vidal, Rene Corbo and their fellow Contra-supporters 
by their participation in this drug smuggling network was being used to 
help finance the purchase of military equipment, ammunition and 
explosives needed by the Contras to wage their private war against the 
Sandinista government. 

50.12. This drug smuggling dimension of the John Hull-International 
Brigade caused David to seriously consider fleeing from the operation. 
But he did not. 

The La Penca Press Conference Bombing 

50.12.1. Carlos asked David to explain the role which members of 
this International Brigade of Contras had played in the 
May 30, 1984 terrorist bombing attack on the Eden 
Pastora press conference at La Penca, Nicaragua. 

50.12.2. David went into great detail explaining this role 
informing Carlos that David had been personally informed 
of his information by Alvaro Cruz and Frederico Saenz, 

the two men on John Hull's ranch under whose direct 
supervision David operated in his activities as part of 
the Contra International Brigade. 

50.12.3. Cruz and Saenz had informed David that the prePminary 
decision to assassinate Eden Pastora had been made by 
John Hull, Felipe Vidal, Rene Corbo and Adolfo Calero in 
a series of meetings in or around January of 1984 — 
when it became clear to these men that Pastora was 
neither going to allow non-indigenous Nicaraguans, such 
as the Cuban-Americans, to participate in his Costa 
Rican-based ARDE military effort against the Nicaraguan 
government nor was Pastora going to allow his Costa 
Rican-based ARDE forces to be melded into a unified 
Contra command under the leadership of Adolfo Calero's 



Honduran-bascd FDN Contra force. 

50.12.4. David reported that this January, 1984 preliminary 
decision to kill Pastora had been made in meetings held 
on John HulTs ranch among Hull, Vidal and Corbo and, 
later, between these men and Adolfo Calero in Honduras. 

50.12.5. Other sources reported that this preliminary decision 

was finalized in a meeting in Miami, Florida in February i 
of 1984, between Vidal and Corbo and their "sponsor" ! 
Francisco "Paco" Chanes. ] 

50.12.6. It was Cruz and Saenz who informed David of the 1984 
decision to conduct the bombing of Pastora. Other 
sources set forth below hav^e verified specific steps in 
this chain of events. They arc as follows: 

50.12.7. In February of 1984, Felipe Vidal and Rene Corbo flew 
from San Jose, Costa Rica to Miami, Florida - where 
they met personally with Francisco "Paco" Chanes. 
Chanes was the de facto owner of two Miami-based seafood 
import companies. These were Ocean Hunter, Inc. and Mr. 
Shrimp. These two private companies were, in fact, the 
vehicles through which Francisco "Paco" Chanes smuggled 
into the United States up to one full ton of Colombian 
cocaine eiich week from Jorge Ochoa and Pablo Escobar, 
via John Hull's Costa Rican ranch. "Paco" Chanes was 
also an ardent financial supporter of the ultra right- 
wing, Miami-based, Cuban anti-communist organization 
"Brigade 2506," Silent partners in Chanes' two "seafood 
import" companies were Frank Castro and Rolando Martinez 
— fellow intense anti-communists. 

50.12.8. In this February, 1984 meeting in Miami held between 
"Paco" Chanes and Vidal and Corbo, Chanes gave his final 
approval to the participation of Vidal and Corbo in the 
assassination of Eden Pastora. 

50.12.9. Vidal and Corbo then sought advice from Chanes as to 
whom they might retain to carry out this assassination. 
Paco Chanes sent Vidal and Corbo to meet with Frank 
Castro and Rolando Martinez. 

50.12.10. Vidal and Corbo met with Frank Castro and Rolando 
Martinez in Miami in February of 1984 and were, in turn, 
sent to see one Niles Heinz. Heinz, in turn, sent Vidal 
and Corbo to meet with one Ramon Cecilio Palacio — a 
man reported to be the "chief of security" in Miami for 
Jorge Ochoa. 

50.12.11. In February of 1984, Vidal and Corbo met, in Miami, with 
Ramon Cecilio Palacio - who placed them in the hands of 


two Cuban brothers introduced to them as Ricardo and 
William "Gris". These two men arc believed by 
Plaintiffs* CounscTs sources to be, in fact, one Raul 
Villavcrdc and one of his two brothers - either Rafael 
(if he was not earlier killed in a yacht explosion in 
Miami) or Jorge, a cocaine smuggler associated with 
Palacio and Ochoa. 

50.12.12. The "Gris" brothers took the men to Chile and introduced 
them to Amac Galil, a notorious international right-wing 
terrorist who was, at the time, working for the dreaded 
secret military police of Chilean dictator Pinochet. 

30.12.13. Galil was paid $50,000 to plan and execute the 
assassination of Eden PaJtora. 

50.12.14. Between March and May of 1984, Amac Galil travelled 
through Panama up into Costa Rica - where he went to 
John HulPs ranch. On John HulTs ranch, Galil obtained 
from John Hull three kilograms of C-4 explosive - 
portions of which had been smuggled onto John Hull's 
ranch through the combined efforts of Defendants 
Theodore Shackley, Thomas Clincs, Richard Sccord, Albert 
Hakim, Rafael "Chi Chi" Quintcro, John Hull, Bruce 
Jones, Thomas Posey, Ronald Martin, James McCoy, and 
Mario Delamico. 

50.12.15. John Hull met repeatedly with Galil while Galil was in 
Costa Rica. Indeed, John Hull travelled with Galil, by 
car, from HulPs ranch, up to the Nicaraguan border, 
where Galil took numerous photographs of the area, and 
then returned with Hull to Hull's ranch. These facts 
have been independently corroborated by Plaintiffs' 
Counsel by direct interviews between our investigators 
and two sources who were eyewitnesses to Galil's 
presence on John Hull's ranch prior to the La Penca 
bombing. These are Sources #32 and #33. 

50.12.16. In May of 1984, Amac Galil left John Hull's ranch and 
took up residence at the Grand Via in San Jose, where he 
used the false identity of a Danish journalist by the 
name of Per Anker Hansen. 

50.12.17. Under this false identity, Galil obtained employment 
with a Swedish film crew and, later, obtained access to 
the press conference held by Eden Pastora at La Penca on 
May 30, 1984. 

50.12.18. Galil detonated the C-4 bomb concealed in an aluminum 
camera case - using a remote control radio transmitter 
— killing, maiming, and severely injuring the 
international journalists and parties listed in the 


Plaintiffs' Complaint on May 30, 1984. 

50.12.19. As described by Cruz and Saenz to David, Galii escaped 
in the following manner: he fled using a truck owned by 
Defendant Hull with assistance of various of the other 

Kidnappings, Death Threats, and Murder 

51. At the conclusion of one of the several interviews held between Carlos 
and David in a public park in San Jose, Costa Rica, in 1985, David and 
Carlos were seized on the sidewalk next to the park by a small group of 
armed men whom David later identified to Carlos as associates of John Hull 
and Hull's International Brigade of Contras. 

These men forced David and Carlos, at gunpoint, onto the floor of the 
back seat of a car and drove them, for hours, to the main ranch of John 
Hull, at the northern border of Costa Rica. There David and Carlos were 
held by an armed guard, in a small wooden shed, while the other men went "to 
contact John." 

David told Carlos that David was sure that the men were going to kill 
David and Carlos when they returned so he persuaded Carlos to join with 
him in an escape. David and Carlos attacked the lone armed guard left to 
detain them, broke the window out of the shed in which they were held 
captive, and fled into the forest — amid a hail of gunfire from their 

52. After days and nights spent in the forest, David and Carlos came to a 
road, obtained a ride on a truck to a small village - and Carlos telephoned 
Tony Avirgan and asked that Avirgan come to get them. 

53. David refused to go with Avirgan and effect his escape, wanting to get 
away from the situation which was threatening his life. So, David left 
Carlos, who waited in a park to be picked up by Tony Avirgan. David 
promised, however, that he would contact Carlos to let Carlos know that 
David was safe." 

The Plaintiffs were later informed by a member of the Costa Rican Rural 
Guard, Source #34, that an agent of the Costa Rican Rural Guard placed 
undercover on John Hull's ranch. Source #35, reported to Costa Rican 
authorities that he had later seen David recaptured and physically brought 
to John Hull's ranch where David was beaten and tortured to death on John 
Hull's ranch. 

54. Carlos reported his kidnapping to the Costa Rican legal authorities and 
these authorities searched, with Carlos, for the property, and the wooden 

David did not call and the next day Carlos, trailed by Avirgan and a 
Costa Rican police officer, found David in the Central Market area. David 
assured Carlos that he was fine and would soon leave the country and from 
there would be in touch. Neither Carlos nor the Plaintiffs ever heard from 
or saw David again. 


shed, where Carlos and David had been held. This search by the authorities 
lead to the ranch of John Hull on the Costa Rican-Nicaraguan border. 

55. Soon after the reported recapture and torture-execution of David, 
Plaintiffs Tony Avirgan and Martha Honey began to receive telephoned death 
threats - ordering them "to stop your investigation or be killed.** These 
threats then began to take the form of notes, made up of letters from the 
alphabet cut from magazines, notes which were physically placed under the 
door of their home — where they lived with their two small children. 

These death threats, and similar death threats directed to their 
employees and office staff, required the Plaintiffs to spend thousands of 
dollars to install a physical security system in their office and home. The 
continued death threats required the Plaintiffs to send their children out 
of the country to stay with the Plaintiffs' family in New York State and 
to live Hinder an armed guard provided to them by the Costa Rican legal 
authorities, Source #36. 

56. After a thorough investigation of the information provided to them by 
David, by Carlos - and by numerous other sources; including Costa Rican law 
enforcement authorities. Sources #37 and #38; ARDE Intelligence Officials, 
Sources #39 and #40; interviews with Defendant Felipe Vidal himself. Source 
#41; and interviews with former Contra members. Sources #42, #43, #44, and 
#45 - Plaintiffs Tony Avirgan and Martha Honey prepared a written report of 
their findings and publicly released this report at a press conference held 

in San Jose, Costa Rica In the Fall of 1985. 

57. After this report, Carlos Rojas Chinchilla was kidnapped, a second 

time, by associates of John Hull. These men seized Carlos from his house in 
San Jose and, at gunpoint, ordered him to copy, in his own handwriting, a 
prepared statement they showed him - stating that he had been told nothing 
by David about John Hull - and that his earlier reports filed with the 
Costa Rican legal authorities about David's reports, and Carlos' kidnapping 
by associates of John Hull's were all made up by Carlos at the demand of 
journalists Tony Avirgan and Martha Honey. 

Carlos was told by these men that, after writing this, Carlos would be 
released, unharmed but that, in two weeks time, Carlos would, again, be 
contacted by these men and brought before a "specially selected" group of 
journalists where Carlos was to publicly release his written statement and 
renounce his police reports about John Hull. 

After writing the demanded statement, Carlos was released and he 
fled to Tony Avirgan and Martha Honey and requested protection. 

The Plaintiffs assisted Carlos in escaping from Costa Rica with his 
family and secured a safe place for him to remain until he was called 
upon to testify in the trial of John Hull. 

All of these facts have been verified directly to Plaintiffs' Counsel 
Daniel Sheehan in personal interviews between Attorney Sheehan and Carlos 
Rojas Chinchilla. 

58. In the Fall of 1985, Defendant John Hull sued Plaintiffs Avirgan and 
Honey in Costa Rica, charging them with criminal libel. 

59. In the Fall of 1985, I was contacted by a Source, Source #46, and was 


informed about Plaintiffs Avirgan and Honey's information from David and 

their numerous other sources — and, finding thai this information was 

closely related to information provided to the Christie Institute by our 

Sources regarding the smuggling of guns, ammunition and explosives to John 

HulPs ranch from Florida, via Ilopango Air Force Base in El Salvador, I 

asked that my Source #46 have Tony Avirgan and Martha Honey contact me so 

we could cooperate in our respective investigations. 

60. For a period of time. Source #46 communicated information back and 
forth between our Christie Institute investigation and Tony Avirgan and 
Martha Honey. 

In December of 1985, my law office was asked by Tony Avirgan and Martha 
Honey to assist in the preparation of their defense against the charges of 
criminal libel in Costa Rica. We agreed to do so. 

The Secret Team 

61. During my preliminary investigation of the information in the 
possession of Tony Avirgan, Martha Honey and their sources - I was contacted 
by Source #47, a right-wing para-military specialist, former U.S. Army pilot 
in Vietnam and military reform specialist in January of 1986. 

Source #47, the Specialist, who was unaware of my investigation, 
informed me that he had met - at a right-wing function - a former U.S. 
military intelligence officer. Source #48, interested in seeing to it that 
the Mujahedin forces in Afghanistan were supplied with safe and effective 
military equipment with which to combat the Soviet invasion of their 

Source #47 informed me, however, that, upon his second meeting with 
Source #48. this source began to discuss with Source #47 the existence of a 
"Secret Team" of former high-ranking American CIA officials, former high- 
ranking U.S. military officials and Middle Eastern arms merchants -- who 
also specialized in the performance of covert political assassinations of 
communists and "enemies" of this "Secret Team" which carried on its own, 
independent, American foreign policy - regardless of the will of Congress, 
the will of the President, or even the will of the American Central 
Intelligence Agency. 

Source #47 was so shocked at this information that he wanted me to meet 
with Source #48, to interview him, and to evaluate the information this man 

I agreed to do so. The meeting was set up for February, 1986, at the 
home of Source #47 outside of Washington, D.C. 

The Wilson Connection in Iran 

62. In February of 1986, I went to the house of Source #47, and was 
introduced to Source #48. He was a former U.S. intelligence officer who 
served in Iran in 1976 and for a period thereafter. 

In our interviews. Source #48 set forth the details of a highly secret 
assassination project which operated in Iran from 1976 until the fall of the 
Shah - under the supervision of Defendant Theodore Shackley and Defendant 


Thomas Clincs. This project was supervised, in the Middle East by one Edwin 
Wilson. Source #48 who worked as an anti-terrorist specialist in the 
U.S. Military Mission in Iran, was in a special position to have personal 
knowledge about the project run by Edwin Wilson - since Wilson's program 
operated under the rubric of an "anti-terrorist" project. 

Source #48 set forth, in detail, how this covert "anti-terrorist" 
search and destroy operation was set up, in 1976, under the overall 
supervision of the Assistant Deputy Director of Operations for the American 
Central Intelligence Agency - Theodore Shackley, and his Deputy, Thomas 
Clines. However, Source #48 was convinced that this operation became a 
criminal, privately run, non-CIA authorized program as of 1977 - after 
President Jimmy Carter and CIA Director Stansfield Turner entered the 

This privately-run, "anti-terrorist" assassination program was 
authorised and controlled by Theodore Shackley and Thomas Clines - in their 
purely private, non-governmental capacity, from 1977 to 1979. 

During this 1977 to 1979 period, Edwin Wilson, in his private capacity 
as the field director of this private Shackley-Clines project, established 
contact, in Libya, with Mohammar Gadhafi and secretly agreed to train Libyan 
anti-Shah of Iran terrorists in the use of deadly C-4 explosives at five 
secret terrorist training camps located inside Libya. While entirely 
criminal in nature, Edwin Wilson's activities with these Libyan terrorists 
were actually intelligence-gathering activities - designed to put into his 
hands the identities, missions and targets of the Libyan, anti-Shah 
terrorist operations. 

Once this intelligence information was obtained by Wilson in his 
capacity as a trainer and supplier for the terrorists, Wilson would secretly 
communicate the identities, and mission of particular terrorists to Rafael 
"Chi Chi" Quintero - who was responsible for "interdicting" and directing 
the assassination of these Libyan terrorists. 

Indeed, part of the "mission" of Wilson inside Libya was to carry out 
the assassination of Mohammar Gadhafi himself. Pursuant to this plan, 
Wilson arranged for Gadhafi's plane to be "wired-up" and bombed. The plane 
was blown up - but, at the last moment before the plane took off, Gadhafi 
returned from the tarmac to receive a telephone call. Several East German 
agents were killed in the explosion. 

This operation of Wilson's was "blown" when one of Wilson's associates 
here in the United States, one Kevin Mulcahey, unknowingly revealed to a 
person friendly with an agent of the Federal Bureau of Alcohol, Tobacco and 
Firearms, that his boss, Edwin Wilson, was training and supplying Libyan 

Wilson and his associate Frank Terpil were indicted for their dealings 
with Gadhafi - but his supervisors, Theodore Shackley and Thomas Clines, 
were allowed to resign from the CIA by CIA Director Stansfield Turner and 
Deputy Director Frank Carlucci. 

However, upon resigning. Defendants Shackley and Clines joined with 
Defendants Secord and Hakim and "went private" - continuing to run their 
"Secret Team" - complete with it's own covert foreign policy. 

Plaintiffs' Counsel learned this information not only from Source #48, 
but also from Source #49 - who is a retired CIA officer with knowledge about 
this operation and a Source #50 - who is a former Air Force officer of the 
Special Investigation Office who investigated Edwin Wilson's activities in 



the Middle East. 

Source #49 has had direct conversations with Source #50 who was 
directly involved with Edwin Wilson in this Middle Eastern Operation. 

Supplying the Contras 

Source #49 has direct knowledge that it was this "Secret Team" of 
Defendant Shackley, Defendant Clines, Defendant Secord and Defendant Hakim - 
operating through their business partnership with Edwin Wilson named the 
Egyptian-American Transport and Service Company (incorporated in January of 
1979) who first established contact with and began secretly supplying 
weapons, ammunition and C-4 explosives to the Contras soon after they began 
operations in Honduras in August of 1979 and who later, under a separate 
corporate cover, supplied C-4 explosives and military equipment to the 
Contras, through John Hull, in Costa Rica in 1983 and 1984. The "Field 
Officer" for this "Secret Team" was Defendant Rafael "Chi Chi" Quintero, 
the man who met with the field commanders of the Contras in Honduras and the 
Contra associates of John Hull in Costa Rica to take their "orders" for 
weapons and explosives and who saw to it that said military supplies were 
delivered. Defendant Quintero conducted his activities on behalf of this 
Secret Team through a Florida-based corporation named Orca Supply Company - 
a company earlier set-up by Edwin Wilson. 

This information was obtained by Plaintiffs' Counsel from Source #49 
and from persons who have spoken directly with persons directly involved in 
this operation. 

Under the supervision of Defendant Theodore Shackley, Defendants Thomas 
Clincs, Richard Secord, Albert Hakim and Rafael Quintero have been directly 
responsible for the private supplying of military equipment - including the 
C-4 explosives supplied to John Hull in 1983 and 1984 which were used in the 
terrorist bombing attack at La Penca on May 30, 1984. Indeed, a close 
associate of Defendant Quintero trained persons in Honduras to make deadly 
C-4 anti-personnel terrorist bombs identical to the one used at La Penca. 
This individual was one John L W. Harper. These Defendants were 
responsible for the entire supply of weapons, ammunition and explosives to 
the Contras in Honduras and Costa Rica from August of 1979 up to October of 
1986 " with the exception of the time period between June of 1981 and March 
of 1984, during which time American CIA Director William Casey and his agent 
Vincent M. Cannistraro supplied such materials. 

Defendants Martin, McCoy, Delamico, Posey and Chancs contributed 
military supplies directly to this flow of equipment supplied by Defendants 
Shackley, Clines, Secord, and Hakim during this time period - including a 
portion of the C-4 used to construct the C-4 bomb used at La Penca in the 
attempted assassination of Eden Pastora. 

Moreover, Ricardo and William "Gris" are reported, by a source. Source 
#51 - a former Contra member active in the Miami area with direct knowledge 
of the Miami Contra community - to be one Raul Villaverdc and his brother, 
either Rafael or Jorge Villaverdc. The Villaverde brothers are close 
associates of Defendant Rafael Quintero, who worked with Defendant Quintero 
as professional assassins for Edwin Wilson in Iran and Libya between 1976 
and 1980. According to Source #51, it was in Iran and Libya, while working 
for Wilson, that Raul and Rafael Villaverde met Amac Galil, the right-wing, 


anti-Gadhafi Libyan terrorist whom the Defendants actually procured to carry 
out the La Penca bombing. 

63. In April of 1986. Plaintiffs' Counsel was introduced to Source #52 a 
high-ranking, active. Central Intelligence Agency official who discussed 

with Sources #48 and #49 the activities of Defendant Shackley and Clines and 
confirmed to them a number of the facts set forth above. 

64. At that time. Plaintiffs' Counsel also met personally with Source #53 
another high-ranking, active. Central Intelligence Agency official, who 
confirmed much of the data concerning the political environment and 
activities of persons involved in the Contra movement in Costa Rica in 1984 
- and the names of the persons involved in the Contra operations in Costa 
Rica in 1984. at the time of the La Penca bombing. 

65. In early 1986. Plaintiffs' Counsel established contact with Source #54 
a man actively engaged in the trafficking of cocaine with Defendant 
Francisco "Paco" Chancs and Defendant Dagoberto Nunez, which source 
communicated to Plaintiffs' Counsel detailed information confirming the 
participation of Defendants Chanes. Nunez, and Hull in the smuggling of 
cocaine into the United States through Miami and Memphis. Source #54 
supplied Plaintiffs' Counsel with the names and whereabouts of some half- 
dozen pilots who flew guns, ammunition and C-4 explosives from the United 
States to John Hull's ranch in Costa Rica - and who flew cocaine back into 
the United States from Defendant Hull's ranch. A number of these pilots 
have been located and contacted by Plaintiffs' Counsel, but they insist upon 
immunity from criminal prosecution in exchange for their testimony against 
the Defendants in this case. These pilots constitute Sources #54, #55 #56 
#57, #58. and #59. ' 

66^ Plaintiffs' Counsel has established direct contact with Edwin Wilson 
who IS serving a federal prison term in excess of 50 years at Marion Prison 
in Illinois and has spent hours in private interviews of Wilson. Mr Wilson 
also requests immunity from criminal prosection in exchange for his 
testimony demonstrpting the truthfulness of the information set forth above 
about his activities with Defendants Shackley. Clines. Secord, Hakim and 
Quintero. Edwin Wilson is Plaintiffs' Source #60. 

67. Plaintiffs' Counsel has also personally interviewed Source #61 a Costa 
R. can pilot with intimate knowledge of the cocaine smuggling operations of 
Defendants Hull and Nunez - and of the fact that the income from their 
smuggling activities is being used to fiance the Contra operations of the 
Defendants in Costa Rica. Source #61 introduced Plaintiffs' Counsel to 
Source #62. a Roman Catholic Priest from Costa Rica who has personally 
interviewed numerous peasants in Costa Rica who have come to know with 
direct personal knowledge of Defendants Hull and Nunez cocaine smuggling 
operations - and their partnership in these operations with Defendant 
Francisco "Paco" Chancs in Miami. 

68. Plaintiffs' Counsel's investigators have interviewed Sources #63 #64 

who tJ. Z^^ ,V\'''''''7/^''u,' °'" ^^"« Enforcement Administration 

who are directly knowledgeable concerning the cocaine smuggling operation of 


Defendants Chanes, Vidal, Corbo, Nunez, Hull, Ochoa and Escobar and the use 
of a portion of the profits from this enterprise to fund their Contra 
operations in Costa Rica. 

69. Plaintiffs' Counsel has personally interviewed Source #66, an active 
Florida state law enforcement intelligence officer, who is familiar with the 
drug smuggling — and illegal gunrunning operations of the defendants — but 
who has been directed to "stand clear" from his investigation of their 

The First "Contra War": Organized Crime and Right-wing Terror-Politics 

70. Sources #48 and #49 j^jcscribed above, as well as Sources #67 and #68, 
who are tenured professors at accredited universities in the U.S. who 
conduct professional research into government documents, interview persons 
in the U.S. intelligence community, and teach accredited courses regarding 
the history of the activities of our American intelligence community — as 
well as Source #69, who is a retired official of the United States Customs 
Department and the Federal Bureau of Narcotics and Dangerous Drugs (now the 
Drug Enforcement Administration), and Source #70, who is a former Southeast 
Asian Border Police officer, and Source #71, who is a retired CIA official - 
- have communicated evidence to Plaintiffs' Counsel which constitutes 
probable cause to believe that the following facts are true regarding the 
Defendants in this case: 

70.1. That, in late 1959, immediately after Fidel Castro drove 
Dictator Batista out of Cuba, former United States Vice President 
Richard M Nixon established, and chaired, a Special Committee within 
the United States National Security Council with the express assignment 
of developing -- and executing — a plan by means of which to mount a 
covert "Contra" war against the socialist government of Cuba, utilizing 
expatriate indigenous right-wing Cubans who had been loyal to Dictator 
Batista. The objective of this non-Congressionally authorized 
operation was to undermine, weaken, and eventually, overthrow the 
revolutionary socialist government of Cuba. It appears that this 
secret operation was then code-named "Operation 40." 

70.2. That, in late 1959, then Vice President Richard M. Nixon, 
with the direct participation and cooperation of United States Central 
Intelligence Agency Director Allen Dulles, undertook the supervision of 
the recruiting of expatriate, right-wing Cubans who had fled from Cuba 
to Miami, Florida — and caused to be established two secret military 
training bases for their "Contra" forces, one south of Miami, Florida, 

and one in Guatemala. CIA Director Allan Dulles assigned CIA Agent and 
former Marine Corps officer Carl Jenkins to supervise the training of 
these "Contra" forces in guerilla warfare tactics in Florida and 
Guatemala. The objective of this Nixon-Dulles supervised operation was 
to train and to secretly infiltrate these expatriate Cubans back into 
Cuba, where they would set up centers of guerilla military resistance 
to the Castro-led socialist government. These forces would also mount 
terrorist military attacks against the economic infra-structure of 


Cuba, making it difficult for the new revolutionary government to 
organize and operate the economy. 

70.3. With this covert NSC-CIA program underway in early 1960, then 
Vice President Richard M. Nixon secretly "reached out" to one Robert 
Maheu, the Chief of Staff and de facto Director of billionaire Howard 
Hughes* financial empire. At the time Maheu was working with Nixon on 

a secret, non-Congressionally approved project which may have involved 
underwater activities and been named "Operation Desktop". Because of 
Maheu's secret status known only to Richard Nixon and President 
Eisenhower, Richard Nixon selected Maheu to attend an equally secret 
meeting, in early 1960, in Florida, with two men representing former 
Havana Mafia "Don" Santo Trafficante - whose fabulously wealthy Havana 
Casino, Hotel and prostitution operation run by Resorts International, 
Inc. (a Meyer Lansky Mafia company) had been driven out of Cuba, along 
with Trafficante's business associate Batista in 1959. 

70.4. At this early 1960 Florida meeting between Robert Maheu 
(representing Richard Nixon ) and John Roselli and Sam Giancana 
(representing Santo Trafficante, a Meyer Lansky Mafia Lieutenant), it 
was agreed between Richard Nixon and Santo Trafficante that the NSC's 
secret Operation 40 would be secretly "supplemented" by secreting, 
within this operation, a "private" sub-operation which was to be 
supervised directly by the Mafia's Havana Lieutenant Santo Trafficante. 
This secret, "private" unit was to be a political assasslnatloD unit 
assigned to murder Cuban President Fidel Castro, his brother Raul 
Castro. Che Guevera and five other revolutionary Cuban government 

Former associates of Cuban dictator Batista and of Resorts 
International boss Santo Trafficante were, according to this early 1960 
Nixon-Trafficante agreement, to be selected out of the Operation 40 
participants by Santo Trafficante - and then secretly trained, as 
political assassins, by Trafficante and his Mafia associates, at a 
secret "Triangular-Fire Training Base" to be located in Mexico. Those 
selected from Operation 40 by Santo Trafficante to become members of 
the "Shooter Team" were: 


Rafael "Chi Chi" Quintero; 


Felix Rodriguez (AKA "Max Gomez"); 


Luis Posada Carriles (AKA "Ramon Medina**); 


Rafael Villaverde; 


Raul Villaverde; 


Ricardo Chavez; 


Frank Fiorini (AKA Frank Sturgis); 


Rolando Martinez; and two other Cuban Americans. 

One of the "supervisors" of the group was to be E. Howard Hunt, 
code-named "Eduardo." 

This secret "Shooter Team" began training in early 1960. 

''OJ. When John F. Kennedy received the Democratic Party nomination 

for President in the Summer of 1960, he was briefed by a CIA officer 


about the existence of Operation 40 and its objectives -- but it does 
not appear that he or Robert Kennedy were ever briefed about the 
existence of the Shooter Team. However the Shooter Team continued to 
tram - and. indeed, between I960 and 1963, initiated several efforts 
to assassinate Cuban President Fidel Castro. 

'°'^-.„ . January of 1961 and April of 1961, the low-profile 

gucrilla-inf titration strategy of Operation 40 was transmuted in a plan' 
for a full-scale military invasion of Cuba, to be staged at the now- 
infamous Bay of Pigs. This invasion, using the personnel of Operation 
40, failed disastrously in April of 1961. 

70.7. However, by June of 1961. Robert Kennedy had rc-grouped the 
tattered remnants of the old Operation 40 forces and re-initiated the 

old low*-profiIc. strategy of infiltration and guerrilla "raids" into 
SlJtV J ! Operation 40 was named "Operation Mongoose." This 

fZ JuJ^of .o7,\"'m""'k'^ ""y'''" •^""^^y Administration 

irom June of 1961 to November of 1963. 

Th-«H '^\!:''^"'"^°\?^ "Operation Mongoose" was. then 34.year-old, 
Theodore Shackley. His Deputy was Thomas Clines 
Lieutenli'r' °P"''';°%/."''ctioning in a working partnership with Mafia 
Lieutenant Santo Trafficante. operated from a base located in a few 

the «o7rlr?„"„ University of Miami. This base - and 

the operation itself - came to be called "JM/Wave" 

operations - and their associated Trafficante- 
lead political assassination sub-operation - were directed by Theodore 
Shackley and Thomas Clines from 1961 to 1963. mcoaore 

70.8. During 1963. several participants in Operation 40 were caueht 
smuggling narcotics into the U.S. from Cuba and the use. by tie ' 
program, of former Batista and Trafficante criminal associates in the 
program began to cause "problems of control" of illegal "pro teering " 

;;e'"ShoTrTeam."" ^''"''"-^ " « ''^^ ^P"--- of 

Daflas. Texas. °^ ^""^^^ assassinated in 

70.10. In 1965. "Operation Mongoose." and JM/Wave wen* .i,..t a,.^^ 
and Jheodore Shackley and his D/puty,' Thoma^Sre? w7r7 t^sfer^rld" to 

The Move to Southeast Asia: Political Assassination Financed by Opium 

s?alion for thiri!"' T''=o<'o;'= Shackley was made the Deputy Chief of 
station for the CIA in Laos. Thomas Clines became his Deputy. 

n?nvi-i.w • Shackley and Thomas Clines secretly 

whTch Van"p,'r'"''' ^''^ ^ «hree-sided war in 

which Van Pao was engaged, in Laos, for control of part of the illeaal 
opium trade in that nation. During 1965. Van Pao's competitors in ?hl 


,t 'J i li l lt i!JLj l.' 'i f .. ' ^ * i. 'i .lMU.g W t 

opium trafficking business were mysteriously assassinated. 

By 1966, Van Pao was one of the major opium producers and 
traffickers in Laos. 

70.13. Under the direction of Deputy Chief of Station Theodore 
Shackley and his Deputy, Thomas Clines, a secret program was pursued to 
train indigenous Hmong tribesmen in guerilla war tactics for use in 
"unconventional warfare" activities. These activities included the art 

of political assassination. Starting in 1966, their "special 

operations" with the Hmong tribesmen began to be secretly financed by 

Van Pao. 

70.14. In 1964, a "Special Operations Group" was established in 
Saigon, Vict Nam. This group was a multi-service, military operation 
known as the Military Assistance Command, Vietnam Special Operations 
Group (MACV-SOG) or the Joint Task Force for unconventional warfare. 

This group, among other tasks, "supervised" the secret political 
assassination activities of this secret unit of Hmong tribesmen -- 
though the group operated, in fact, under the supervision of Theodore 
Shackley and Thomas Clincs. 

From 1966 to 1968, the commander of the Special Operations Group, 
which supervised the political assassination program in Laos, Cambodia, 
and Thailand, was Defendant General John K. Singlaub. 

Serving under Singlaub in Laos for a period at the end of 1968 was 
a young 2nd Lt. by the name of Oliver North. 

The Deputy Air Wing Commander for the Special Operations Group was 
then Air Force Lt. Col. Richard Sccord out of Udorn AFB, Thailand. His 
superior was then Col. Harry C. "Hcinic" Aderholt. 

One of the members of the Army Special Forces units in the Group 
was one Dwight Owen - the older brother of Defendant Robert Owen. 

Between 1966 and 1971, this Special Operations Group based in Laos 
was, in fact, under the supervision of Theodore Shackley and Thomas 
Clincs. During the period from 1966 to 1975, this Special Operations 
Group in Laos, through the secret Hmong tribesmen unit funded by a 
portion of Van Pao's opium income, secretly assassinated over 100,000 
non-combatant village mayors, book-keepers, clerks and other civilian 
bureaucrats in the countries of Laos, Cambodia and Thailand. 

70.15. In 1966, Theodore Shackley became CIA Chief of Station in 
Laos when former Station Chief Gordon Jorgenson was made Chief of 
Station in Vietnam. Thomas Clincs continued to be a Deputy to Shackley 
in Laos. In early 1968, Shackley became Chief of Station in Saigon. 

70.16. In 1968, Theodore Shackley's former associate in the JM/Wave 
program in Miami, Mafia Lieutenant Santo Traf f icante, flew from Tampa, 
Florida, to Southeast Asia where he met at a hotel in Saigon with 
Shackley's Laotian associate Van Pao. In this meeting, Santo 
Trafficantc agreed to become a partner with Van Pao in the importation 

of China White heroin into the United States. By 1969, Santo 
Trafficantc had become the #1 importer and distributor of China White 
heroin in America. Van Pao's profits increased accordingly ~ as did 
his financial contribution to the secret Hmong tribesmen assassination 


and "unconventional warfare" project supervised by Theodore Shackley 
and Thomas Clincs in Laos, Cambodia and Thailand. 

70.17. In early 1972, Theodore Shackley and Thomas Clines were 
transferred from Saigon to the United States, where Theodore Shackley 
became the Chief of the CIA's Western Hemisphere operations. Thomas 
Clines became his Deputy. This division of the CIA directs the 
operations of the CIA in Central and Latin America. 

From this post, Theodore Shackley and Thomas Clines directed the 
operation known as "Track IP in Chile which directed the political 
assassination of Chilean socialist President Salvador Allende and his 
Chief of Staff in Chile and the military overthrow of the 
democratically elected government of Chile in September of 1973. 

70.18. Shortly before the successful overthrow of the socialist 
Chilean government in September of 1973, Theodore Shackley and Thomas 
Clines were transferred to Langley, Virginia; Shackley headed the East 
Asia Division with Clines as his Deputy. 

70.19. From this post at Langley, Theodore Shackley and Thomas 
Clincs directed the Phoenix Project in Vietnam in 1974 and 1975 which 
carried out the secret mission of assassinating members of the economic 
and political bureaucracy inside Vietnam to cripple the ability of that 
nation to function after the total US withdrawal from Vietnam. This 
Phoenix Project, during its history, carried out the political 
assassination, in Vietnam, of some 60,000 village mayors, treasurers, 
school teachers and other non-Viet Cong administrators. 

70.20. Theodore Shackley and Thomas Clines financed a highly 
intensified phase of the Phoenix Project, in 1974 and 1975, by causing 
an intense flow of Van Pao opium money to be secretly brought into 
Vietnam for this purpose. 

This Van Pao opium money was administered for Theodore Shackley 
and Thomas Clincs by a US Navy official based in Saigon's US office of 
Naval Operations by the name of Richard Armitage. 

Armitage functioned as the "bursar" for their Van Pao opium funds 
into the Vietnam Phoenix Project from 1973 to the fall of Vietnam in 
April of 1975. 

The Birth of the Secret Team 

70.21. However, because Theodore Shackley, Thomas Clines and Richard 
Armitage knew that their secret anti-communist extermination program 

was going to be shut down in Vietnam, Laos, Cambodia, and Thailand in 
the very near future, they, in 1973, began a highly secret non-CIA 
authorized program setting up their own private anti-communist 
assassination and unconventional warfare program - to operate after 
the end of the Vietnam campaign. 

70.22. Thus, from late 1973 until April of 1975, Theodore Shackley, 
Thomas Clines and Richard Armitage disbursed, from the secret, Laotian- 


based. Van Pao opium fund, vastly more money than was required to 
finance even the highly intensified Phoenix Project in Vietnam. The 
money in excess of that used in Vietnam was secretly smuggled out of 
Vietnam in large suitcases, by Richard Secord and Thomas Clines - and 
carried into Australia, where it was deposited in a secret, personal 
bank account (privately accessible to Theodore Shackley, Thomas Clines 
and Richard Secord). 

During this same period of time between 1973 and 1975, Theodore 
Shackley and Thomas Clines caused thousands of tons of U.S. weapons, 
ammunition, and explosives to be secretly taken from Vietnam and stored 
at a secret "cache" hidden inside Thailand. The Van Pao monies in this 
secret Australian account and this large cache of stolen US weapons 
hidden deep inside Thailand were to be used by Theodore Shackley, 
Thomas Clines, Richard Secord, Richard Armitage and the right-wing 
covert operations operatives they could persuade to join their "off- 
lincs", private "secret team" after the conclusion of the Vietnam 

70.23. The "liaison officer" to Shackley and Clines and the Phoenix 
Project in Vietnam, during this 1973 to 1975 period, from the "40 
Committee" in the Nixon White House was one Eric Von Marbod - an 
Assistant Secretary of State for Far Eastern Affairs. Von Marbod 
shared his information about the Phoenix Project directly with his 
supervisor Henry Kissinger. 

70.24. Saigon fell to the Vietnamese in April of 1975. The Vietnam 
War was over. 

Pott-Vletnam: Drugs, Arms Scams and Terror Contioue 

70.25. Immediately upon the conclusion of the evacuation of U.S. 
personnel form Vietnam, Richard Armitage was dispatched, by Theodore 
Shackley and Thomas Clines, from Vietnam to Tehran, Iran. 

70.26. In Iran, Armitage (the -bursar"for the Van Pao opium money 
for Shackley and Clines* planned "Secret Team" covert operations 
program), between May and August of 1975, set up a secret "financial 
conduit" inside Iran, into which secret Van Pao drug funds could be 
deposited from Southeast Asia. The purpose of this conduit was to 

serve as the vehicle for secret funding, by Shackley's "Secret Team," 
of a private, non-CIA authorized "Black" operations inside Iran - 
disposed to seek out, identify, and assassinate socialist and communist 
sympathizers -- who were viewed by Shackley and his "Secret Team" 
members to be "potential terrorists" against the Shah of Iran's 
government in Iran. 

70.27. In late 1975 and early 1976, Theodore Shackley and Thomas 
CImes retained Edwin Wilson to travel to Tehran, Iran to head up the 

Secret Team" covert "anti-terrorist" assassination program in Iran. 
This was not a U.S. government-authorized operation. This was a 
private operation supervised, directed and participated in by Shackley, 


Clincs, Sccord and Armitagc in their purely private capacities. 

70.28. At the end of 1975, Richard Armitagc took the post of a 
"Special Consultant" to the U.S. Department of Defense regarding 
American military personnel Missing In Action (MIAs) in Southeast Asia. 
In this capacity, Armitagc was posted in the U.S. Embassy in Bangkok, 

There Armitagc had top responsibility for locating and retrieving 
American MIA's in Southeast Asia. He worked at the Embassy with an 
associate, one Jerry O. Daniels. 

From 1975 to 1977, Armitagc held this post in Thailand. However, 
he did not perform the duties of this office. Instead, Armitagc 
continued to function as the "bursar" for Theodore Shacklcy's "Secret 
Team," seeing to it that secret Van Pao opium funds were conducted from 
Laos, through Armitagc in Thailand to both Tehran and the secret 
Shackley bank account in Australia at the Nugen-Hand Bank. The monies 
conducted by Armitagc to Tehran were to fund Edwin Wilson's secret 
anti-terrorist "seek and destroy" operation on behalf of Theodore 

Armitagc also devoted a portion of his time, between 1975 and 
1977, in Bangkok, facilitating the escape from Laos, Cambodia and 
Thailand and the re-location elsewhere in the world, of numbers of the 
secret Hmong tribesmen group which had carried out the covert political 
assassination program for Theodore Shackley in Southeast Asia between 
1966 and 1975. Assisting Richard Armitagc in this operation was Jerry 
O. Daniels. Indeed, Jerry O. Daniels was a "bag-man" for Richard 
Armitagc, assisting Armitagc by physically transporting out of Thailand 
millions of dollars of Van Pao's secret opium money - to finance the 
re-location of Theodore Shackley's Hmong tribesmen and to supply funds 
to Theodore Shackley's "Secret Team" operations. 

At the U.S. Embassy in Bangkok, Richard Armitagc also supervised 
the removal of arms, ammunition and explosives from the secret 
Shackley-Clincs cache of munitions hidden inside Thailand between 1973 
and 1975 - for use by Shackley's "Secret Team." Assisting Armitagc in 
this latter operations was one Daniel Arnold, the CIA Chief of Station 
in Thailand - who joined Shacklcy's Secret Team - in his purely 
private capacity. 

The U.S. Ambassador to Thailand, one Morton Abramowitz, came to 
know of Armitage's involvement in the secret handling of Van Pao opium 
funds and caused to be initiated an internal State Department heroin 
smuggling investigations directed against Richard Armitagc. 

Armitagc was the target of Embassy personnel complaints to the 
effect that he was utterly failing to perform his duties on behalf of 
American MIAs, and he reluctantly resigned as the D.O.D. Special 
Consultant on MIA*s at the end of 1977. 

From 1977 until 1979, Armitagc remained in Bangkok opening and 
operating a business named The Far East Trading Company. This company 
had offices only in Bangkok and in Washington, D.C. This company was, 
in fact, from 1977 to 1979, merely a "front" for Armitage's secret 
operations conducting Van Pao opium money out of Southeast Asia to 
Tehran and the Nugen-Hand Bank in Australia to fund the ultra right- 
wing, private anti-communist "anti-terrorist" assassination program and 


•unconventional warfare" operation of Theodore Shackicy's and Thomas 
Cline's "Secret Team." During this period, between 1975 and 1979, in 
Bangkok, Richard Armitage lived in the home of Heinie Aderholt the 
former Air Wing Commander of Shacklcy's "Special Operations Group" in 
Laos who, between 1966 and 1968, had served as the immediate 
superior to Richard Secord, the Deputy Air Wing Commander of MACV-SOG. 
Sccord, in 1975, was transferred from Vietnam to Tehran, Iran. 

Early "Irjin Arms DeaP Profit-SkimmiDg 

70.29. In 1976, Richard Secord moved to Tehran, Iran and became the 
Deputy Assistant Secretary of Defense in Iran, in charge of the Middle 
Eastern Division of the Defense Security Assistance Administration. In 

this capacity, Secord functioned as the chief operations officer for 
the U.S. Defense Department in the Middle East in charge of foreign 
military sales of U.S. aircraft, weapons and military equipment to 
Middle Eastern nations allied to the U.S.. Secord's immediate superior 
was Eric Von Marbod - the former 40 Committee liaison officer to 
Theodore Shacklcy's Phoenix program in Vietnam from 1973 to 1975. 

70.30. From 1976 to 1979, in Iran, Richard Secord supervised the 
sale of U.S. military aircraft and weapons to Middle Eastern Nations. 
However, Richard Secord did not authorize direct nation-to-nation sales 
of such equipment directly from the U.S. government to said Middle 
Eastern governments. Instead, Richard Secord conducted such sales 
through a "middle-man", one Albert Hakim. 

By the use of middle-man Albert Hakim, Deputy Assistant Secretary 
of Defense Richard Secord purchased U.S. military aircraft and weapons 
from the U.S. government at the low "manufacturer's cost" - but sold 
these U.S. aircraft and weapons to the client Middle Eastern nations at 
the much higher "replacement cost." Secord then caused to be paid to 
the U.S. government, out of the actual sale price obtained, only the 
lower amount equal to the lower manufacturer's cost. The difference, 
was secreted from the U.S. government. Secord and Albert Hakim 
secretly transferred these millions of dollars into Shackley's "Secret 
Team" operations inside Iran - and into Shackley's secret Nugen-Hand 
bank account in Australia. Thus, by 1976, Defendant Albert Hakim had 
become a partner with Thomas Clines, Richard Secord and Richard 
Armitage in Theodore Shackley's "Secret Team." 

70JI. Between 1976 and 1979, Shackley, Clines, Secord, Hakim, 

Wilson, and Armitage set up several corporations and subsidiaries 
around the world through which to conceal the operations of the Secret 
Team. Many of these corporations were set up in Switzerland. Some of 
these were: (1) Lake Resources, Inc.; (2) The Stanford Technology 
Trading Group, Inc.; and (3) Companie dc Services Fiduciares. Other 
companies were set up in Central America, such as: (4) CSF, 
Investments, Ltd. and (5) Udall Research Corporation. Some were set up 
inside the United States by Edwin Wilson. Some of these were: (6) Orca 
Supply Company in Florida and (7) Consultants International in 
Washington, D.C. 


Through these corporations, members of Theodore Shacklcy's "Secret 
Team** laundered hundreds of millions of dollars of secret Van Pao opium 
money and pilfered Foreign Military Sales proceeds between 1976 and 

70.32. In January of 1979, Theodore Shackley, Thomas Clines, Richard 
Sccord and Albert Hakim made Edwin Wilson a full partner in their 
"Secret Team" gunrunning board, establishing the corporation named the 
Egyptian-American Transport and Services Corporation. 

The Contra Coonectioa: The Secret Team Bargains with Somoza 

70.33. In the Spring of 1978, Shackley, Clines, Secord and Hakim 
directed Edwin Wilson to travel to Nicaragua to make available to 
Nicaraguan dictator Anastasio Somoza. the private assassination 
services of Shackley's "Secret Team" - the objective of which was to 
carry out the location of and the political assassination of the top 
leadership of the Sandinista revolutionary movement. This contract was 
tendered, and Wilson offered the assassination services of Shackley's 
•Secret Team" to Somoza, in the Spring of 1978, for the sum of $650,000 
per year. This offer included the services of five (5) "counter- 
subversion specialists," at the price of $80,000 per year each and an 
annual expense account of $250,000 for the operation. One the five 
•specialists" was to be Defendant Rafael "Chi Chi" Quintero. The 
others were to be members of the 1960 Richard Nixon-Santo Trafficantc 
"Shooter Team" assembled for Operation 40 (members of which were used 
as "operatives" for Shackley's political assassination operations form 
1961 to the present). 

Somoza felt that the price tag was too high for this project so 
he continued to negotiate for a lower price. 

Persons who know of this 1978 approach to Somoza by Wilson on 
behalf of Shacklcy, Clines, Secord and Hakim are one Douglas 
Schlachter, Source #72, (presently in the Federal Witness Protection 
Program), one Christine Simmons, Source #73, and former United States 
Congressman Charles Wilson, Source #74. 

70.34. Again, in the Spring of 1979, Theodore Shackley, Thomas 
Clines, Albert Hakim and Richard Secord sent Edwin Wilson to arrange a 
contract relationship between the "Secret Team" and Nicaraguan dictator 
Anastasio Somoza. 

This time, the contract offer was to supply military equipment, 
ammunition and explosives to Somoza - since Somoza's dictatorial 
government had been cut off from any supply of military equipment from 
the U.S. by President Jimmy Carter's invocation of the Harkin Amendment 
m early 1979. 

While Edwin Wilson's trip to Somoza in the Spring of 1979 did not 
result in the establishment of this contract, the trip of Rafael "Chi 
Chi" Quintero, later, did. Thus, by early 1979, Theodore Shackley, 
Thomas Clines, Albert Hakim and Richard Secord (all partners together 
in this Egyptian-American Transport and Service Company) had a formal 
contractual relationship with Nicaraguan dictator Anastasio Somoza 


pursuant to which tjiis "Secret Team" supplied weapons, ammunition, 
aircraft and explosives to Somoza's Nicaraguan government - despite 
the formal order of the United Slates President Jimmy Carter that no 
military equipment of any kind was to be provided to Somoza's 
Nicaraguan government. 

70.35. Neither President Carter nor his Director of Central 
Intelligence, Stansficld Turner, knew or approved of the conduct of 
Theodore Shackley and his partners who supervised the Secret Team - 
because Shackley and Clines had been ordered by Stansfield Turner to 
resign from the CIA in late 1978 or early 1979 - when Turner learned 
that Shackley and Clines were business partners with Edwin Wilson who 
was going to be publicly indicted (based on the disclosures of Kevin 
Mulcahey) for unlawfully supplying military explosives and weapons to 

70.36. From March to July of 1979, Shackley's "Secret Team" supplied 
military equipment to Somoza in his capacity as the Dictator of 
Nicaragua. The man who met regularly with Somoza's representative to 
arrange these weapons shipments was Rafael "Chi Chi" Quintero. 

The CIA Takes the Ball 

70.37. When Somoza fled from Nicaragua on July 17, 1979, he 

travelled to an island in the Bahamas named North Cay. There he met 
with Rafael "Chi Chi" Quintero and other representatives of Theodore 
Shackley and his Secret Team associates. 

In their July, 1979 meetings on North Cay, representatives of 
Theodore Shackley, Thomas Clines, Richard Secord and Albert Hakim 
entered into a contract to supply aircraft, weapons, ammunition, and 
military explosive to Somoza and his La Guardia Generals who had fled 
Nicaragua with him, to enable them, now as "Contras", to plan and 
prosecute - against the U.S. government-recognized Sandinista 
government of Nicaragua - a secret covert Contra war virtually 
identical to the one which Theodore Shackley and Thomas Clines had 
supervised against the socialist revolutionary government of Cuba from 
1961 to 1965. 

The man who met regularly with the Contra military field 
commanders, to advise them as to what weapons-and equipment they 
needed - and to see to it that this equipment was supplied to the 
Contras from 1979, through 1980, into 1981, was Rafael "Chi Chi" 
Quintero. He conducted his weapons supply activities through the 
Miami-based company named Orca Supply Company, a company set up by 
Edwin Wilson. 

These secret supply operation to the Contras by Shackley's "Secret 
Team" continued until June of 1981 - when the United States CIA 
Officially (though covertly) took over this operation and assigned 
Vincent M. Cannistraro to take the place of Rafael "Chi Chi" Quintero 
as the Supply Officer" for the Contra operation. 


North Turns to the Secret Team When Congress Bans Aid 

70.38. When the United States Congress was drafting the Boland 
Amendment in late 1983 to order the CIA and the White House to cease 
all United States Executive Department aid to the Contras, Lt. Colonel 
Oliver North contacted Theodore Shackley, Thomas Clincs, Albert Hakim 
and Richard Secord and had the "Secret Team" re-activate its military 
supply of the Contras' operations which also included the John Hull 
Contra operation in Costa Rica on the "Southern Front" against 
Nicaragua. Rafael Quintero, again, became the "Supply Officer" for the 
Honduran and Costa Rican Contra operations. 

70.39. As of March of 1984, the Defendants' "Secret Team" was, once 
again, back in charge of the secret supplying of aircraft, weapons, 
ammunition and military explosives to the Contra forces in Honduras and 
through John HulTs ranch in Costa Rica. 

It was between March of 1984 and May of 1984 that Defendants 
Shacklcy, Clines, Secord, Hakim, Quintero, et al. supplied to John Hull 
~ along with Defendants Posey, Martin, McCoy, Delamico et al. the 
C-4 military explosives used by the right-wing Libyan terrorist Amac 
Galil to bomb the May 30, 1984 La Penca press conference of Eden 

70.40. It was also this same group of men who supplied the C-4 
explosives that were to be used in the terrorists' bombing attack 
against the United States Embassy in Costa Rica in July of 1985, 
described in the Plaintiffs' Amended Complaint. 

White House Uses Secret Team Again for Iranian Arms Deal 
Profits go to the Contra Operations 

71. Also, when Ronald Reagan, Edwin Meese, William Casey, and Robert 
McFarlanc, John Poindexter and Oliver North decided, in 1985 and 1986, to 
undertake the secret sale of arms to Iran, it was, once again, this "Secret 
Team" of Theodore Shackley, Thomas Clines, Albert Hakim and Richard Secord 
to whom they went to carry out this "black" mission. Plaintiff's sources 
for this information are Sources #49 and #50. They arc the sources for all 
the information in paragraph 71. 

71.L This "Secret Team" employed its tried and tested procedure of 

purchasing the military equipment from the U.S. Pentagon at 
"manufacturer's cost" and selling the equipment to Iran at "replacement 
cost" - and conducted the "excess" profit earned in the sale, through 
Lake Resources, Inc., Companie de Services Fiduciares and in to its 
Grand Cayman account in the name of CSF Investments, Ltd. - where the 
"Secret Team" kept on deposit the funds which it secretly used to 
finance its Contra war against the socialist government of Nicaragua. 

71.2. Secret Team member Richard Secord purchased short take-off 

and landing (STOL) airplanes for the Contra forces in Honduras and 
Costa Rica - which planes were used to ferry weapons and explosives 


into John Hull's farm from Ilopango Air Force Base in El Salvador. 
Sccord purchased there four STOL aircraft from Maule Inc., paying for 
said aircraft with two checks one drawn on the account of CSF 
Investments, Ltd. and the other drawn on the account of Udall Research 

'^^•3- Rafael "Chi Chi" Quintero personally participated in the 

supervision of the construction of the dirt landing strips inside Costa 
Rica which were used for the smuggling into Costa Rica of weapons, 
ammunition, and military explosives - the construction of which secret 
landing strips were financed by checks drawn on the account of Udall 
Research Corporation. 

7^1.4. Defendants Albert Hakim, Richard Sccord and Thomas Clines arc 

all associated with the company of Stanford Technology, Inc. and 

Stanford Technology Trading Group, Inc.. The registered agent of the 

office of Stanford Technology Trading Group, Inc. located in 

Switzerland is also the registered President of CSF Investments, Ltd. 

in the Grand Cayman Islands and Defendant Hakim has paid an official 

court settlement of a private lawsuit with a check drawn on the account 

of CSF Investments, Ltd.. 

Telephone calls placed from the secret "safe house" in El 
Salvador, where Eugene Hasenfus and the other crew members who flew 
arms and munitions to the Contra forces in Central America lived, went 
to the offices of Secord's, Clines' and Hakim's company Stanford 
Technology, Inc.. 

72, Plaintiffs' Counsel has a direct eyewitness, Source #75. who can 
identify Felix Rodriguez as the man who, along with Luis Posada Carriles, 
supervised the unloading of weapons and ammunition flown in from Florida to 
Ilopango Air Force Base in El Salvador by Defendant Thomas Posey and who 
then trans-shipped said equipment to Defendant John Hull's ranch in Costa 

And Plaintiffs' Counsel has a source. Source #76, who can testify that 
this same Felix Rodriguez is, in fact, a long-timc employee of Defendant 
Theodore Shackley indeed, that this Felix Rodriguez has, for many years 
worked as an employee of Defendant Shackley in Theodore Shackley's private 
"Secret Team" weapons supply and assassination program. 




73. Plaintiffs' Counsel represents to the Court that he is in contact with 
other sources who possess further, first-hand, evidence proving the 
truthfulness of the civil and criminal charges made against the 29 
Defendants in the Plaintiffs' Amended Complaint - and that these sources 
include Eden Pastora himself. Source #77, high-ranking officials in the 
Costa Rican government and elsewhere. Sources #78 and #79, - which the 
Court's short 20 day period allowed for the Plaintiffs' preparation of their 
Opposition to the Defendants' Motion to Dismiss did not allow Plaintiffs' 
Counsel adequate time to contact. 

74. Plaintiffs' Counsel also represents to the Court that Plaintiffs would 
easily be able to provide numerous additional sources to prove the 
truthfulness of the facts set forth in this Attorney's Affidavit, if the 
Court were to afford the Plaintiffs the standard opportunity for civil 

75. Also, Plaintiffs' Counsel asks that the Court take Judicial Notice of 
the fact that numerous reports have been published in The New York Times . 
Thp Wa?hinRt9n Pq§^ The San Francisco Examiner , and many other national 
newspapers setting forth details of the conduct of some of the Defendants in 
this civil action which corroborate their participation in the covert 
criminal enterprise to violate the United States Neutrality Act by 
unlawfully waging war against the nation of Nicaragua - which is the 
"enterprise- reported by the Plaintiffs to this Court in May of 1986. While 
such reports are certainly not dispositive of the issue of the Defendants' 
participation in the criminal enterprise described in the Plaintiffs' 
Amended Complaint, the fact that the Plaintiffs and the Plaintiffs' Counsel 
have been the source of information to the Court, so much of which has now 
been publicly revealed to the Court by the national media and by Congress to 
have been entirely accurate, most certainly should dispel any remaining 
doubts that the Court may have had, at one time, that Defendants' Attorney 
Ted Kline was incorrect when he publicly asserted to the media that "The 
Plaintiffs' case is just a Clown Act". This case is no "Clown Act". It is 

a serious endeavor to bring the legal process of the Judicial Branch of our 
Federal government to expose, to evidence, and to prove the factual 
assertions made against the Defendants in this case by the Plaintiffs. 

76. Plaintiffs alio ask the Court to take Judicial Notice of the fact that 
Defendants Richard Secord and Robert Owen appeared before United States 
Congressional committees on December 9th and 10th of this year and asserted, 
under oath, that their being required to testify about their possible 
participation in a criminal enterprise to covertly provide funds and weapons 
to the Central American Contra forces would result in testimony which would 
tend to incriminate them or provide direct evidence of their guilt of some 

of the federal crimes with which the Plaintiffs' Counsel publicly charged 
them before this Court on May of 1986. 

Surely this conduct of only the first of the Defendants named in this 
federal civil suit to be placed under oath and asked about their 
participation in the criminal "enterprise" alleged in this Complaint is 
probative of the criminal guilt of the Defendants of some of the crimes 


charged in this Complaint. 

77. Plaintiffs and Plaintiffs* Counsel, The Christie Institute, possess 
evidence constituting "probable cause" that each of the Defendants named in 
this Complaint are guilty of the conduct charged. 

If further detailed evidence is required by the Court to allow the 
Plaintiffs to begin the standard process of discovery in this case, the 
failure to place it in this Affidavit is the function of the short time 
allowed by the Court for the preparation of this filing — it is not because 
the Plaintiffs lack such evidence. 

Daniel P. Sheehan 


Martha Honey watches as her husband, Tony Avirgan, arrives at the hospital to be treated for 
injuries suffered at the La Penca bombing. Photo: Maria Esquivel, 

Attorney Daniel P. Sheehan: General Counsel for Tony Avirgan, Photo by Julio Lainez, Tico Times. 
the Christie Institute, Sheehan leads its effort to 
bring the private citizens behind the Contras to jus- 


John Hull during his libel trial against Martha Honey, 

Avirgan and Honey, Hull's suit was dismissed. Photo by Julio Lainez, Tico Times. 

Photo by Julio Lainez, Tico Times. 

Moments after the explosion. Tony Avirgan is in the checkered shin. Reid Miller 
of Associated Press is in a white shirt. Photo by Jose Venegas. La Nacion . 

Major General John K. Singlaub, U.S. Army (Ret.): 
He openly helped organize the illegal private 
contra supply network in the United States. 

Major General Richard Secord. U.S. Air Force (Ret.): 
A principal Secret Team member, he illegally uses 
drug pro fits to provide contra guns and explosives. 
Photo: U.S. Air Force 


Selected Index 

Abramowitz, Morton (38) 
Adcrholt, Hcinic (35), (39) 
Allen, Richard (14) 

Armitagc. Richard (36), (37), (38), (39) 
Arnold, Daniel (38) 

Avirgan, Tony (1), (14), (17), (21), (26), (27X^28) 
Brigade 2506 (24) 

Bush, Vice President George (14), (16) 
Calcro, Aldofo (13), (22), (23), (24) 
Cannisiraro, Vincent M. (15), (30), (41) 
Carlucci, Frank (29) 
Carr, Steven (12) 
Carriles, Luis Posada (33), (43) 
Carter, President Jimmy (14), (29), (41) 
Casey, William (14). (15), (16), (30), (42) 
Castro, Fidel (32), (33), (34) 
Castro, Frank (24) 

Chanes, Francisco "Paco" (24), (30), (31), (32) 
Chavez, Ricardo (33) 

Chinchilla, Carlos Rojas (17), (18), (19), (20), (21), (23), (26) 

Civilian Military Assistance (10), (11) 
Claridgc, Duanc "Dewey" (22) 

Clincs, Thomas (25), (29), (30), (31), (34), (35), (36), (37), (38) 
(39), (40), (41), (42), (43) v / ^ ^ 

Cocaine (19), (22), (23), (24), (25), (31) 

I t 

1 »i<'.rr.vy?*y,;r^fww^6 ^ ?i y7f r wtfv ^^ 

Companic dc Services Fiduciares (39), (42) 
Consultants International (39) 
Corbo, Rene (23), (24), (32) 

Costa Rica (10), (11), (13), (18), (19), (20), (21), (22), (24), (25), 
(26), (27). (28), (30), (31), (32), (42), (43) 

Cruz, Alvaro (23), (24), (26) 

CSF Investments (42), (43) 

Daniels, Jerry O. (38) 

David (18). (19), (20), (21), (22). (23). (24), (26), (27). (28) 
Dclamico, Mario (25). (30). (42) 
Dulles, Allen (32) 

Egyptian-American Transport and Service Company (30), (40) 

Eisenhower, President Dwight (33) 

El Salvador (4), (5), (11). (15), (28). (43) 

Escobar, Pablo (19). (23). (24), (32) 

Far East Trading Company (38) 

Federal Emergency Management Agency (FEMA) (5), (6), (7) 

Fiorini, Frank (33) 

40 Committee (37), (39) 

Friends of the Americas (8) 

Galil, Amac (25), (26), (30), (42) 
Garcia, Jesus (11) 
Giancana, Sam (33) 
Glibbcry, Peter (12) 
Gomez, Max (33) 
Gordon, Jorgenson (35) 
Grand Cayman (42), (43) 



Gray and Company (16) 
Gris Brothers (25), (30) 

Hakim, Albert (25), (29), (30), (31), (39), (40), (41), (42), (43) 
Hansen, Per Anker (25) 
Hascnfus, Eugene (43) 
Heinz, Nilcs (24) 

Honey. Martha (1), (14), (17), (21), (27), (28) 

Hull, John (1 1), (12), (13), (14), (17), (18), (19), (20), (21), (22), 

(23), (24), (25), (26), (27). (28), (30), (31), (32). (42), 

Hunt, E. Howard (33) 
Ilopango Air Base (II). (28), (43) 

International Brigade (18), (19), (20), (21), (22), (23), (26) 
Iran (28), (29), (30), (37), (39), (42) 
Jenkins, Carl (32) 
Jenkins, Woody (8) 
JM/Wave (34), (35) 
Jones, Bruce (12), (14), (20), (22), (25) 
Kennedy, Presic'ent John F. (1), (33), (34) 
Kennedy, Robert (34) 
Kissinger, Henry (37) 
Lake Resources, Inc. (39), (42) 
Lansky, Meyer (33) 
Mafia (33), (34), (35) 
Mahcu, Robert (33) 

Martin, Ronald Joseph, Sr. (25), (30), (42) 
Martinez. Rolando (24), (33) 


^ *» *« 

Mattes, Jim (12) 

Maulc Inc. (43) 

McCoy, James (25), (30), (42) 

McFarlanc, Robert (16), (42) 

Medina, Ramon (33) 

Mccse, Edwin (7), (14), (16), (42) 

Merki, Staccy (3), (4), (12) 

MIAs (38) 

Mitchell, Attorney General John (7) 
Mr. Shrimp (24) 

Nicaragua (4), (4), (8), (9), (10), (11), (14), (15), (16), (18), 
(19), (21), (22), (23), (40). (41), (42), (44) 

Nixon, Former President Richard (3), (7), (32), (33), (37), (40) 

North, Lt. Col Oliver (12), (13), (16), (35), (42) 

Nugcn-Hand Bank (34), (38), (39) 

Nunez, Moises Dagoberto (31), (32) 

Ocean Hunter, Inc. (24) 

Ochoa, Jorge (19), (23). (24), (25), (32) 

Operation 40 (32), (33), (34), (40) 

Operation Mongoose (34) 

Opium (34), (35), (36), (37), (38), (40) 

Orca Supply Company (30), (39), (41) 

Owen, Dwight (35) 

Owen, Robert (12), (13), (16), (35), (44) 
Palacio, Ramon Cecilio (24), (25) 

Pastora, Eden (10), (13), (19), (22), (23), (24), (25), (30), (42), 


Phoenix Project (36), (37), (39) 
Poindcxtcr, John (42) 

Posey. Tom (10). (11). (12). (13). (14). (20). (25). (30). (42). (43) 
Project Cable Splicer (7) 

Quintcro, Rafael^Xhi Chi" (25), (29), (30), (31). (33), (40), (41). 

Reagan, President Ronald (4), (5), (6), (7), (14), (15), (16), (42) 

Resorts International (33) 

REX 84 (5), (6), (7) 

Rodriguez. Feliz (33), (43) 

Roselli. John (33) 

Saenz, Frcdcrico (23), (24), (26) 

Schlachter. Douglas (40) 

(35). (3.,. 

Secret Team (^J). (29, (30,(36). (37). (38). (39). (40). (41). 

Shacklcy. Theodore (25). (28). (29). (30). (31). (34) (35) (36^ 
(37). (37). (38). (39). (40). (il). (ij) '(43) " ^ 

Shcehan, Daniel (J), (27). (45) 

Singlaub, Major General John K. (16). (35) 

Somoza. Anastasio (14). (15). (22). (40), (41) 

Special Operations Group (35). (39) 

Stanford Technology Trading Group. Inc. (39). (43) 
State Defense Force (5). (6). (8) 
Sturgis. Frank (33) 
Tambs. Lewis (19), (20) 
Terpil, Frank (29) 

Trafficantc, Santo (33). (34), (35), (40) 

Turner, Siansficld (29), (41) 

Udall Research Corporation (39), (43) 

United States Council on World Freedom (16) 

Van Pao (34), (35), (36), (37), (38), (40) 

Vidal, Felipe (23), (24), (27), (32) 

Villavcrde, Rafael (25) 

Villaverde, Raul (25), (30). (33) * 

Von Marbod, Eric (37), (39) 

Wilson, Congressman Charles (40) 

Wilson, Edwin (29), (30). (31), (37), (38), (39), (40), (41)